Conflicts of interest are a central focus for the SEC. Indeed, conflicts are at the core of many of the actions brought against regulated entities. And, an undisclosed conflict was at the center of actions brought against a hedge fund, its founder, general... Read More
Conflicts of interest are at the center of two administrative proceedings recently instituted by the SEC. One involved the failure to adequately disclose the conflict. The other focuses on a failure to institute appropriate supervisory procedures for... Read More
We were recently introduced to Fraud Examiner Expert Tracy Coenen , in her book " Expert Fraud Investigation: A Step-By-Step Guide " she details the steps a company should go through in performing a fraud investigation. Coenen provides the... Read More
On September 19, 2011, the Securities and Exchange Commission (the " SEC ") issued a release (the " Release ") proposing new rule 127B (the " Proposed Rule ") under the Securities Act, which would prohibit "material... Read More
Conflicts of interest and a failure to disclose related party transactions continue to be key themes in Commission actions involving investment advisers. Undisclosed conflicts, as well as a failure to disclose related party transactions, were at the center... Read More
As summer draws to a close, the Commission continued its work under Dodd-Frank, issuing a staff study on financial literacy. It focuses on what investors want to know about financial professionals and investment products. Proposed rules were also issued... Read More
The Commission filed another settled action based on undisclosed conflicts involving an investment adviser. In this proceeding Respondents, principals of the adviser, failed to disclose a fee splitting arrangement with an executing broker. In the Matter... Read More