Hugh Kennedy
If you are an investment adviser registered or required to be registered under section 203 of the Act (15 U.S.C. 80b-3), it is a fraudulent, ...
(a) Prohibition. It shall constitute a fraudulent, deceptive, or manipulative act, practice, or course of business within the meaning of section 206(4) of the Act ...
(a) Exclusion. A family office, as defined in this section, shall not be considered to be an investment adviser for purpose of the Act. (b) ...
(a) Client. You may deem the following to be a single client for purposes of section 202(a)(30) of the Act (15 U.S.C. 80b-2(a)(30)): (1) A ...
Hedge fund advisers are having some advertising and marketing compliance issues and 2015 will see SEC examiners focus on retiring investors. These nuggets were among ...
The first-ever charges against a broker-dealer for failing to protect a customer’s material nonpublic information will result in a $5 million penalty for Wells Fargo ...
The fallout from the 2008 collapse of Lehman Brothers continues. This time the cost is $15 million—the penalty Barclays Capital ($12.9B in AUM) will pay ...
The good news: the SEC found the firm’s compliance manual contained policies and procedures “reasonably designed to prevent several violations of the Advisers Act.” The ...
The new president of the North American Securities Administrators Association began his one-year term last week and simultaneously announced action on one of his stated ...
Hedge fund advisers lured by rapid growth in the more than $300 billion alternative mutual funds market are increasingly becoming involved with the funds either ...