RCW Staff
xaminers have frequently observed deficiencies with respect to the custody rule, and in 2017, OCIE issued a Risk Alert identifying some of the typical deficiencies ...
The complaint alleges that, in reality, there were no private placements. Dougherty was simply running a Ponzi scheme by taking new investor money and using ...
You also represent that in relying on the requested relief to sell common shares of beneficial interest, each Fund will sell newly issued shares ...
Many would say only having four to five hours’ worth of telephone calls and performing a few Google searches doesn’t constitute sufficient due diligence before ...
In a bid to provide greater flexibility to broker-dealers withdrawing their registration, the SEC has approved amendments to FINRA rule 4570 affording firms the option ...
I am pleased to see the first part of the Roadmap, the proposed changes to Part 49, issued today. These proposed changes update the ...
Berkey's customers incurred significant costs with every transaction and the securities were held briefly; thus, the price of the securities had to rise significantly for ...
In marketing materials and other related documents provided to clients, DBTCA disclosed that it relies on an independent, in-house research group (“Research Group”) that uses ...
Lyons and various investment adviser entities with the name Synchrony that Lyons controlled engaged in a scheme to misappropriate assets from hedge funds Lyons and ...
in a newsletter emailed to Fund investors on September 8, 2016, Bruce inaccurately stated that he had “spent a great deal of time doing my ...