September 9, 2019 SEC Risk Alert Puts Spotlight on Principal Trading, Agency Cross Trades On September 4, 2019, the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued another risk…
July 2, 2019 How an LPA’s Definition of Organizational Expenses Can Connect to a Custody Rule Violation For private fund advisers, fee and expense reviews are a cornerstone to a sound compliance program. The SEC repeatedly reinforces…
April 11, 2019 Custody Concerns Continue You timely filed your Form ADV within 90 days of fiscal year end, but, did you properly answer all the…
July 27, 2018 How Do You Supervise for SEC Pay-to-Play Violations? If you wanted more information about the contours of the SEC’s Pay-to-Play Rule, or how the SEC may enforce it,…
July 13, 2018 Do Your Fund Documents Clearly Disclose Receipt of Accelerated Monitoring Fees? Somewhat more reminiscent of the broken-windows enforcement era, two affiliated private equity advisers managing billions settled with the SEC on…
June 26, 2018 SEC Deficiency Letters Require Swift Action On the topic of SEC Deficiency Letters, if you have received one, you must promptly take corrective action. The SEC…
June 1, 2018 Deputy Attorney General Rod Rosenstein Discusses Compliance Program Effectiveness The embattled U.S. Deputy Attorney General Rod Rosenstein recently spoke to compliance pros at the 2018 Annual Conference for Compliance…