Custody Rule cases are rapidly becoming a staple of SEC enforcement. Rule 206(4)-2 requires registered investment advisers with custody of client funds or securities to implement certain controls to protect those assets. Prior to its amendment, effective in March 2010, …
SEC Sanctions Audit Firm, Partner Tied to Custody Rule Read More »
The DOJ reiterated its Yates policy this week under which cooperation credit is conditioned on furnishing the Department with the identity of individuals involved in corporate wrongdoing. Officials also noted that part of cooperation involves furnishing the facts from witness …
This Week In Securities Litigation (Week ending November 20, 2015) Read More »