... Michele L. Schaff and Jeffery E. Schaff. Licensed re-use rights only Annuity Security Insurance Illinois Van Dyke v. White Investment adviser In March 2019, the Illinois Supreme Court shook the relatively aseismic landscape of annuity regulation with its opinion in Van Dyke...

...Arthur L. Zwickel; Keith D. Pisani; Alicia M. Harrison Purpose The purpose of this paper is to provide investment advisers, broker dealers, individual investors and other securities firms with a current and detailed summary of the reporting regime under Sections 13 and 16 of the Securities...

...Alec Koch; Russell G. Ryan; Laura K. Bennett Purpose To provide analysis on several SEC enforcement actions of interest to broker-dealers and investment advisers. Design/methodology/approach The article is organized chronologically based on the dates of the SEC enforcement actions discussed...

...Elaine Greenberg Purpose This paper aims to explain the U.S. Securities and Exchange Commission’s (SEC’s) recent Share Class Selection Disclosure (SCSD) Initiative, which offers potentially favorable settlement terms to investment advisers who self-report to the SEC’s Enforcement Division...

... as it carries out its task of re-evaluating the Rule. Jeffery E. Schaff can be contacted at: jschaff@fiduciaryduty.expert © Michele L. Schaff and Jeffery E. Schaff. 2017 Michele L. Schaff and Jeffery E. Schaff. Licensed re-use rights only Investment adviser Broker Conflict of Interest Rule...

...Nicolas Morgan; Art Zwickel; Thomas A. Zaccaro; Jenifer Q. Doan Purpose To explain the import of a recent enforcement action by the US Securities and Exchange Commission (SEC) against an investment adviser for failing to prevent insider trading against the context of an unsettled legal definition...

... – including, for many firms, registration as an investment adviser, broker-dealer, or both. Originality/value Practical regulatory guidance regarding SEC registration requirements that may reach non-US firms from experienced financial services lawyers specializing in asset management. The SEC charged...

...Kay Gordon Purpose To discuss the requirements and implications of the US Securities and Exchange Commission’s (SEC’s) proposed new Rule 206(4)-4, which would require all SEC-registered investment advisers to adopt and implement written business continuity and transition plans (BCPs) reasonably...

...Jason Daniel Purpose To explain a US Securities and Exchange Commission (SEC) enforcement action against a registered investment adviser to private equity funds for allegedly providing brokerage services in connection with the acquisition and disposition of the securities of portfolio companies...

... compliance program helps investment advisers ensure that clients are not disadvantaged and receive full disclosure about how fund expenses are allocated.”[ 7 ] Remediation and cooperation: As noted in the SEC’s settlement order with KKR, the SEC considered remedial acts taken by KKR...

...Michael S. Caccese; Douglas Y. Charton; Pamela A. Grossetti Purpose – To explain an administrative law judge (ALJ) decision, along with a censure, fine, and industry disbarment, against an investment adviser for misleading advertising and false claims of compliance with Global Investment...

...M. Norman Goldberger; John C. Grugan; Christine O’Neil; Tesia N. Stanley Purpose – To explain the first enforcement action the USA Securities and Exchange Commission (SEC) has brought under “pay to play” rules for investment advisers since those rules were adopted nearly four years ago...

... aggregation feature. Design/methodology/approach – Review and summarize the SEC’s finding’s regarding the adviser’s advisory fee breakpoint discount program, deficiencies in the program identified in SEC examinations, resulting violations of the Investment Advisers Act and its rules, the adviser’s...

...John H. Walsh Purpose – To summarize and interpret a Risk Alert titled “Investment Adviser Due Diligence Processes for Selecting Alternative Investments and their Respective Managers,” issued by the USA Securities and Exchange Commission Office of Compliance Inspections and Examinations...

... furnishes semi-annual and annual reports to investors and files periodic reports with the SEC as required by the Applicable Federal Securities Laws. Securities and exchange commission (SEC) Investment adviser Commodity futures trading commission (CFTC) Commodity pool operator (CPO) Harmonization...

... advisers registered under the Investment Advisers Act of 1940 (the “Advisers Act”) to follow when engaging in block trades for client accounts. Design/methodology/approach – The paper summarizes the SEC's findings regarding the adviser's block trade allocation practices, resulting violations...

...Keith T. Robinson; Joseph P. Kelly, II; Andrea E. Baron Purpose The purpose of this paper is to discuss the implications of an SEC Risk Alert and two FINRA regulatory notices concerning the use of social media by registered investment advisers. Design/methodology/approach The paper analyzes...

.../value The paper provides practical guidance from experienced financial services lawyers. Peter J. Shea can be contacted at: Peter.Shea@KattenLaw.com © Authors 2012 Commodity Futures Trading Commission Commodity pool operator Investment adviser Registered investment company...