A Culture of Compliance

posted in: Compliance | 0

Some really telling quotes by Harvey Pitt, the former SEC Chairman, from a NY Times article about compliance (in reference to SAC Capital Advisors and their (lack of a) culture of compliance): “When it comes to compliance, you have to … Continued

Massachusetts to Fight Reg. D Fraud

posted in: Private Investment Funds | 0

Stating that the Securities and Exchange Commission’s newly allowed hedge fund and private equity ad rule “sets in motion a much easier path for shady operators and outright crooks,” Massachusetts Securities regulator William Galvin announced Monday that he’s setting up a new … Continued

Failing to Supervise Results in Liability

posted in: Compliance | 0

The Securities and Exchange Commission today announced charges against hedge fund adviser Steven A. Cohen for failing to supervise two senior employees and prevent them from insider trading under his watch. The SEC’s Division of Enforcement alleges that Cohen received … Continued

Insider Trading Can get Expensive

posted in: Code of Ethics | 0

The SEC obtained a $13.9 million penalty against former Goldman Sachs board member Rajat K. Gupta for illegally tipping corporate secrets to former hedge fund manager Raj Rajaratnam.  Gupta also is permanently barred from serving as an officer or director … Continued

No Surprise Exams for Most SEC Advisers

posted in: Custody | 0

Most of the investment advisers registered with the SEC who maintain custody of their clients’ investment funds aren’t subject to surprise annual examinations, according to a new federal report. A study released last Monday by the Government Accountability Office found that, … Continued

Did You Know . . .

posted in: SEC Examinations | 0

. . . that an SEC Enforcement action is more likely to result from a sweep examination than from a routine examination? That is because sweep exams are usually spurred when a particular business practice of concern has come to … Continued

SEC Forecasts an Increase in Whistleblower Cases

posted in: Compliance | 0

The SEC recently announced the second-ever Dodd-Frank whistleblower award. Based on data released by the SEC after the first full year of the new Dodd-Frank whistleblower program, as well as  recent remarks by an SEC official, an increasing number of awards … Continued