Simons Says: Non-Reportable Accounts…Or Are They?

Rule 204A-1, Investment Adviser Codes of Ethics (the “Rule”), with a compliance date of January 7, 2005, required reporting by access persons, of their securities holdings and transactions in any securities, with some exceptions such as: (i) Direct obligations of … Read More ›

He That Goes a Borrowing Goes a Sorrowing. ~Benjamin Franklin

The Securities and Exchange Commission (“SEC”) announced on August 10, 2015 that Guggenheim Partners Investment Management LLC (“GPIM”) settled charges that it breached its fiduciary duty by failing to disclose a $50 million loan one of its senior executives (“Executive”) … Read More ›

Proposed Compliance Rule Amendments

On May 20th, 2015 the SEC proposed “…rules, forms, and amendments to modernize and enhance the reporting and disclosure of information by investment advisers and investment companies.” In plain English, that means more information reported to the SEC and the … Read More ›