Record-Breaking SEC Enforcement Actions in FY2014

Record 755 enforcement actions, covering a wide range of misconduct, vs 686 enforcement actions in FY2013 and 734 enforcement actions in FY2012 Obtained orders totaling $4.16 billion in disgorgement and penalties, vs $3.4 billion in FY2013 and $3.1 billion in … Read More ›

Additional Insight on Code of Ethics Questions

Q: Does Rule 204A-1 require reporting on company sponsored (or not sponsored, such as for a spouse) 401(k) plans if the asset type needs to be reported? To answer your question, first we will step back to the requirements. Rule … Read More ›

Guidance on Email Reviews

  Although the SEC expects advisers to conduct email reviews as part of the adviser’s compliance program under Rule 206(4)-7, the Commission and its Staff have not offered much guidance with regard to what that review should entail, including the sample size.  So … Read More ›