Month: September 2017

It is axiomatic that investment advisers are required to the follow dictates of firm operating documents, internal procedures and disclosed policies and procedures. OCIE, when conducting inspections, focuses on such issues. The SEC has brought a series of cases centered …

SEC Sanctions Adviser For Failing To Follow Its Procedures Read More »

Tagged with: , ,

The validity of the SEC ALJs’ under the Constitution’s Appointments Clause is a critical issue the Supreme Court is considering for addition to its docket this term which will begin on the first Monday in October. Petition for Writ of …

SEC ALJs Before the Supreme Court: Will the Court Take The Issue? Read More »

Tagged with: , ,