Compliance Solutions for Investment Advisers

Category Archives: Trade Practices

Important Lessons for SEC Advisers

Sometimes investment advisers busted by the SEC for intentional actions can offer lessons for their more law-abiding brethren. Two actions against investment advisers and certain of their executives are a case in point. One firm allegedly engaged in thousands of principal transactions through an affiliated brokerage firm without informing their clients. The other firm and

FBI Probes High Speed Trading

The Federal Bureau of Investigation has launched a wide-ranging investigation into high-speed trading with an eye on whether some firms are acting on fast-moving market information that isn’t available to other traders.

Undisclosed Principal Transactions

The SEC recently announced charges against two Houston-based investment advisory firms and three executives for engineering thousands of principal transactions through their affiliated brokerage firm without informing their clients. In a principal transaction, an investment adviser acting for its own account or through an affiliated broker-dealer buys a security from a client account or sells

SEC Charges Adviser with Front Running

The SEC has charged a Dallas-based registered investment adviser’s primary equity trader with insider trading and trading ahead of large block trades for the adviser’s clients through one of his wife’s brokerage accounts. The trader failed to report his wife’s accounts and one of his accounts, and holdings and transactions in these accounts to the


So what is cherry-picking?  The SEC gives a good description in a recent enforcement case (In the Matter of MiddleCove Capital, LLC and Noah L. Meyers): “Myers executed his cherry-picking scheme by unfairly allocating trades that had appreciated in value during the course of the day to his personal and business accounts and allocating trades