Recent Posts

Private Investment Funds and Reporting Requirements Under the Ethics Code Rule
Posted on 23 Jun 2010 by Doug Cornelius

As I wrote about yesterday on the code of ethics for an investment adviser , one of the requirements of registering with SEC as an investment adviser is implementing a code of ethics. The most involved part of the code is the extensive reporting requirement... Read More

SEC Votes on Pay to Play
Posted on 30 Jun 2010 by Doug Cornelius

At Wednesday's Open Meeting the Securities and Exchange Commission took up the discussion of their proposed rules on pay-to-play for investment advisers. The proposal is a new Rule 206 (4)-5 under the Investment Advisers Act. The Commission voted... Read More

SEC Commissioner Gallagher: Guidance Is Needed for IA CCOs
Posted on 26 Jun 2015 by Thomas O. Gorman

SEC Commissioner Daniel Gallagher published a statement explaining his dissent in two recent enforcement actions in which the Chief Compliance Officer of an investment adviser was charged, noting that the trend in such actions is toward strict liability... Read More

This Investment Adviser Should Have Listened to Gordon Gekko
Posted on 1 Oct 2010 by Thomas O. Gorman

In the initial Wall Street film, financier Gordon Gekko says the now-famous line "greed is good." In the recently released sequel, Wall Street, Money Never Sleeps , Mr. Gekko repeats the line, noting "now it seems it's legal."... Read More

Jury Convicts Investment Adviser on Multiple Counts of Fraud
Posted on 30 Jul 2014 by Thomas O. Gorman

James Tagliaferri, the former President of TAG Virgin Islands, a registered investment adviser, was found guilty by a jury of one count of investment adviser fraud, six counts of violating the Travel Act, one count of securities fraud and four counts... Read More