Focus Perspective: Advertising Rule

November 4, 2019, the SEC proposed major changes to the Advertising Rule and the Cash Solicitation Rule. We would recommend at least glancing through the 505 pages release, which includes much more detail. At the end of the release are … Read More ›

Focus Perspective: Some Things Just Take Time

Background In 1940, Congress passed the Investment Company Act of 1940 (“Act”), to combat abuses in the investment company industry prior to that time. Recognizing the industry would develop and change over time, the Act gave the SEC the power … Read More ›

Focus Perspective: Risk Alerts

Once upon a time, back in the “Olden Days,” when the SEC’s request list was 11 or 12 items listed on a single page, most of our information about the responsibilities of an investment adviser and the SEC’s examination process … Read More ›

Focus Perspective: Déjà vu all over again

There we were, last week on July 22, talking about disciplinary history policy, and OCIE’s September 12, 2016 Risk Alert, “Examinations of Supervision Practices at Registered Investment Advisers.” Was the SEC spying on us? Has our email been hacked by … Read More ›