Month: June 2020

It is axiomatic that a registered investment adviser has a duty to maintain certain records. Equally fundamental is the fact that when the Commission’s Office of Inspections and Examinations or OCIE calls, the advisory firm has an obligation to produce …

After Failing to Permit OCIE Exams, Commission Files Action Read More »

Tagged with: , ,

The question of whether and how to disclose the payment of 12b-1 and similar fees in connection with the acquisition of mutual fund shares has been at the center of a number of Commission actions. It was the central question …

Failure to Disclose Conflicts Draws Sanctions for Adviser Read More »

Tagged with: , ,