Investment Management Law
A Service of Cipperman & Company LLC (www.cipperman.com)
Investment Management Law: Category Archive for Compliance and Operations

SEC Sanctions and Fines Audit Engagement Partner for Failing to Verify Assets

Posted by Todd Cipperman at 7/18/2011 6:11 AM | Add Comment

New Qualified Client Standards Take Effect on September 19

Posted by Todd Cipperman at 7/13/2011 6:10 AM | Add Comment

CFTC Adopts Expansive Anti-Fraud Rule for Swaps and Commodities

Posted by Todd Cipperman at 7/8/2011 6:34 AM | Add Comment

SEC Sets Aside $5 Million Fine Because Directed Brokerage Rule Was Ambiguous

Posted by Todd Cipperman at 7/5/2011 6:45 AM | Add Comment

SEC Adopts Single Family Office Exclusion from Advisers Act

Posted by Todd Cipperman at 6/29/2011 7:27 AM | Add Comment

SEC Adopts Limited Foreign Private Adviser Exemption

Posted by Todd Cipperman at 6/28/2011 5:43 AM | Add Comment

Exempt Private Fund Advisers Must File ADVs Under New SEC Rules

Posted by Todd Cipperman at 6/27/2011 6:25 AM | Add Comment

SEC Outlines Transition Rules for State vs. Federal Adviser Registration

Posted by Todd Cipperman at 6/24/2011 6:44 AM | Add Comment

Private Equity and Hedge Fund Managers Must File ADVs by February 14, 2012

Posted by Todd Cipperman at 6/23/2011 5:48 AM | Add Comment

SEC's Enforcement Director Warns Defense Lawyers about Tactics

Posted by Todd Cipperman at 6/21/2011 6:27 AM | Add Comment

Adviser and CCO Sanctioned for Commission Kickbacks Received for Directing Trades

Posted by Todd Cipperman at 6/17/2011 5:08 AM | Add Comment

Federal Court Rules that Private Plaintiffs Can't Sue Under Compliance Rule

Posted by Todd Cipperman at 6/15/2011 6:33 AM | Add Comment

OCIE Director Lists Issues that PE Firms Must Address

Posted by Todd Cipperman at 6/13/2011 6:39 AM | Add Comment

Large BD Hit with $10 Million Fine for Favoring Large Clients

Posted by Todd Cipperman at 6/10/2011 5:52 AM | Add Comment

FINRA Imposes $600,000 Fine for Allowing Over-Concentration

Posted by Todd Cipperman at 6/6/2011 6:00 AM | Add Comment

Trader Banned From Industry for Gaming Risk Management System

Posted by Todd Cipperman at 6/2/2011 6:49 AM | Add Comment

SEC Smacks RIA for Weak Compliance Program and CCO

Posted by Todd Cipperman at 5/31/2011 6:54 AM | Add Comment

SEC Adopts Expansive Whistleblower Rules

Posted by Todd Cipperman at 5/26/2011 6:30 AM | Add Comment

Federal Judge Acquits In-House Lawyer of Charges of Lying to Government

Posted by Todd Cipperman at 5/20/2011 5:50 AM | Add Comment

SEC Expects to Raise Bar for Advisers and Fund Managers Charging Performance Fees

Posted by Todd Cipperman at 5/11/2011 6:48 AM | Add Comment

SEC Charges Adviser with Lying about SEC Deficiencies in RFPs

Posted by Todd Cipperman at 5/10/2011 6:32 AM | Add Comment

BD/RIA Sanctioned for Failing to Supervise Firm's Owner/Principal

Posted by Todd Cipperman at 5/5/2011 7:11 AM | Add Comment

SEC Staff Says that Pay-to-Play Rule Does not Extend to Affiliates

Posted by Todd Cipperman at 5/4/2011 6:03 AM | Add Comment

Regulators Propose Expansive Definitions of "Swaps" and "Security-Based Swaps"

Posted by Todd Cipperman at 5/3/2011 6:43 AM | Add Comment

Adviser Charged with Marking-the-Close to Inflate Customer Statements

Posted by Todd Cipperman at 4/26/2011 6:17 AM | Add Comment

SEC Brings Action for Falsely Claiming Federal Registration Eligibility

Posted by Todd Cipperman at 4/13/2011 6:07 AM | Add Comment

CCO Sanctioned/Fined for Inadequate Policies/Procedures

Posted by Todd Cipperman at 4/8/2011 7:00 AM | Add Comment

Pennsylvania Securities Regulator Allows 6 More Months to Complete New ADV

Posted by Todd Cipperman at 4/7/2011 5:29 AM | Add Comment

FINRA Proposes Outsourcing Rule

Posted by Todd Cipperman at 4/6/2011 5:19 AM | Add Comment

FINRA Fines Clearing Firm for Failing to Monitor Shorts

Posted by Todd Cipperman at 3/29/2011 9:05 AM | Add Comment

Private Equity Consultant Charged with Insider Trading in Acquisition Target

Posted by Todd Cipperman at 3/28/2011 7:50 AM | Add Comment

Pay-to-Play Rule Answers Provided By IM Staff

Posted by Todd Cipperman at 3/25/2011 5:37 AM | Add Comment

FINRA Chief Outlines Adviser Regulatory Regime

Posted by Todd Cipperman at 3/23/2011 4:47 AM | Add Comment

SEC Will Focus on Conflicts of Interest When Examining Private Equity Firms

Posted by Todd Cipperman at 3/22/2011 6:48 AM | Add Comment

IM Staff Answers Some ADV Part 2 Questions

Posted by Todd Cipperman at 3/21/2011 6:12 AM | Add Comment

Study Shows that Firms Should Lawyer-Up When Charged by FINRA and SEC

Posted by Todd Cipperman at 3/18/2011 5:43 AM | Add Comment

New SEC Budget Includes 102 New Jobs Focused on Private Funds

Posted by Todd Cipperman at 3/17/2011 6:06 AM | Add Comment

Adviser and Principals Including CCO Punished for Weak Compliance Program

Posted by Todd Cipperman at 3/15/2011 6:21 AM | Add Comment

SEC Proposal Would Limit Incentive Compensation at Advisers and Broker-Dealers

Posted by Todd Cipperman at 3/3/2011 8:28 AM | Add Comment

CCO Disciplined for Failing to File Suspicious Activity Reports

Posted by Todd Cipperman at 2/28/2011 6:50 AM | Add Comment

SEC Requires Hedge Fund Manager to Send Enforcement Order to Clients and Prospects

Posted by Todd Cipperman at 2/25/2011 7:00 AM | Add Comment

NASAA Model Custody Rule Would Require Private Funds to Deliver Account Statements

Posted by Todd Cipperman at 2/24/2011 7:14 AM | Add Comment

FINRA Fines BD $600,000 for Allowing Shared Login Credentials

Posted by Todd Cipperman at 2/18/2011 8:06 AM | Add Comment

SEC Sweeping Firms About Social Media

Posted by Todd Cipperman at 2/17/2011 7:01 AM | Add Comment

OCIE Chief Declares New Focus on Enterprise Risk Management

Posted by Todd Cipperman at 2/15/2011 8:03 AM | Add Comment

SEC Commissioner Advocates for Substantive Review of New Advisers

Posted by Todd Cipperman at 2/14/2011 7:18 AM | Add Comment

Ketchum Stumps for BD ADV and Fiduciary Standard

Posted by Todd Cipperman at 2/10/2011 7:27 AM | Add Comment

CFTC Proposes Rescinding Fund Registration Exemptions

Posted by Todd Cipperman at 2/8/2011 8:09 AM | Add Comment

Faulty Computer Coding and Inadequate Compliance Blamed for $200 Million Client Losses

Posted by Todd Cipperman at 2/7/2011 7:07 AM | Add Comment

SEC Sues Lawyer for Altering PPMs in Response to Document Request

Posted by Todd Cipperman at 2/1/2011 6:12 AM | Add Comment

BD Fined $10 Million Because Prop Trading Desk Mis-Used Customer Trading Data

Posted by Todd Cipperman at 1/28/2011 7:09 AM | Add Comment

SEC Sues Adviser for Violating Cross-Trading Rules

Posted by Todd Cipperman at 1/25/2011 7:14 AM | Add Comment

SEC Staff Study Recommends Fiduciary Standard and More Adviser Rules

Posted by Todd Cipperman at 1/24/2011 7:03 AM | Add Comment

SEC Staff Delivers Study on Adviser Examinations

Posted by Todd Cipperman at 1/20/2011 7:08 AM | Add Comment

SEC Proposes Confirm Rule for Security-Based Swaps

Posted by Todd Cipperman at 1/19/2011 6:51 AM | Add Comment

Large BD Will Pay Over $20 Million for Best Execution Violations

Posted by Todd Cipperman at 1/18/2011 7:06 AM | Add Comment

New York State Sues Audit Firm for Violating the Martin Act

Posted by Todd Cipperman at 1/4/2011 8:06 AM | Add Comment

SEC Extends Compliance Date for New Brochure Supplement

Posted by Todd Cipperman at 1/3/2011 7:24 AM | Add Comment

SEC Proposes Municipal Advisor Registration and Disclosure Rules

Posted by Todd Cipperman at 12/21/2010 7:13 AM | Add Comment

SEC Proposals Expand Swaps Regulation

Posted by Todd Cipperman at 12/16/2010 7:36 AM | Add Comment

Law Firm’s IT Pro Charged with Insider Trading

Posted by Todd Cipperman at 12/10/2010 6:48 AM | Add Comment

Non-US Adviser to Pay $1.3 Million for Violating Rule 105

Posted by Todd Cipperman at 12/9/2010 7:15 AM | Add Comment

SEC Chairman Questions Auditor’s Role

Posted by Todd Cipperman at 12/8/2010 7:30 AM | Add Comment

Adviser’s Registration Revoked for Ignoring SEC Exam Staff

Posted by Todd Cipperman at 12/2/2010 7:52 AM | Add Comment

SEC Proposes Swap Reporting Rules

Posted by Todd Cipperman at 11/29/2010 7:07 AM | Add Comment

SEC Proposes Narrow Definition of “Venture Capital Fund” for Registration Exemption

Posted by Todd Cipperman at 11/23/2010 7:03 AM | Add Comment

SEC Proposal Outlines State/Federal Registration, Private Fund Disclosure, and New ADV

Posted by Todd Cipperman at 11/21/2010 10:32 PM | Add Comment

CCO and Firm Sanctioned for Violations of Compliance Rules

Posted by Todd Cipperman at 11/18/2010 7:00 AM | Add Comment

BD President Sanctioned for Failing to Manage Back-Office Ops

Posted by Todd Cipperman at 11/16/2010 6:12 AM | Add Comment

DoL to Require Expanded Investment Option Disclosure for DC Plans

Posted by Todd Cipperman at 11/15/2010 6:33 AM | Add Comment

FINRA Warns Firms to Assess Liquidity Risk Management

Posted by Todd Cipperman at 11/12/2010 7:17 AM | Add Comment

FINRA Wants SRO for RIAs

Posted by Todd Cipperman at 11/9/2010 6:47 AM | Add Comment

SEC Proposes Broad Anti-Fraud Rule for Security-Based Swaps

Posted by Todd Cipperman at 11/5/2010 6:10 AM | Add Comment

SEC Proposes Expansive Whistleblower Rule

Posted by Todd Cipperman at 11/4/2010 5:14 AM | Add Comment

SEC Asks Whether Private Rights of Action Should Apply to Non-US Securities Transactions

Posted by Todd Cipperman at 11/1/2010 6:20 AM | Add Comment

FINRA Conducting Sweep Exams for Public Plan Solicitors

Posted by Todd Cipperman at 10/26/2010 7:41 AM | Add Comment

DoL Proposes Expansion of “Fiduciary” Definition

Posted by Todd Cipperman at 10/25/2010 6:13 AM | Add Comment

SEC Proposal Requires Institutional Managers to Report Certain Proxy Votes

Posted by Todd Cipperman at 10/19/2010 6:28 AM | Add Comment

New Firm Element Training Includes Broad Range of Compliance Topics

Posted by Todd Cipperman at 10/18/2010 8:01 AM | Add Comment

SEC Proposed Rule Would Exclude Single Family Offices from Advisers Act

Posted by Todd Cipperman at 10/13/2010 5:43 AM | Add Comment

No-Action Letter Affirms that 28(e) Research Provider is Not Investment Adviser

Posted by Todd Cipperman at 10/12/2010 6:07 AM | Add Comment

Audit Firm Censured/Fined for Negligent Surprise Custody Exams

Posted by Todd Cipperman at 10/5/2010 5:40 AM | Add Comment

Adviser Prosecuted for Filing with SEC without $25 Million AUM

Posted by Todd Cipperman at 10/4/2010 6:51 AM | Add Comment

SEC Shuts Down Adviser Because of its Weak Compliance Program

Posted by Todd Cipperman at 9/27/2010 6:28 AM | Add Comment

Firm Hit for Allowing Long and Short Positions in Same Securities

Posted by Todd Cipperman at 9/24/2010 6:12 AM | Add Comment

Khuzami Says SEC Reviewing Bonds, Problem Advisers, and Fund Fees

Posted by Todd Cipperman at 9/23/2010 5:01 AM | Add Comment

SEC Proposes More Short-Term Borrowing Disclosures in MD&A

Posted by Todd Cipperman at 9/20/2010 6:55 AM | Add Comment

GC Exonerated in Failure to Supervise Case

Posted by Todd Cipperman at 9/17/2010 7:05 AM | Add Comment

FINRA Wants Complete Termination Details in U5s

Posted by Todd Cipperman at 9/10/2010 7:20 AM | Add Comment

SEC Sanctions BD and President/CCO for Customer Identification Failures

Posted by Todd Cipperman at 9/2/2010 7:33 AM | Add Comment

New SEC Rules Require Shareholder-Nominated Directors in Proxy Statement

Posted by Todd Cipperman at 8/26/2010 6:46 AM | Add Comment

Delaware Court Rules that Hedge Fund LP Has Right to Investor List for Litigation

Posted by Todd Cipperman at 8/19/2010 5:59 AM | Add Comment

SEC Allows Firms to Exclude 529 Plans from Codes of Ethics Reporting

Posted by Todd Cipperman at 8/10/2010 6:45 AM | Add Comment

SEC Publishes Brochure Rule Requiring New Disclosures

Posted by Todd Cipperman at 7/30/2010 6:27 AM | Add Comment

SEC Bars Cherry-Picking Adviser who Claimed Clients Weren’t Harmed

Posted by Todd Cipperman at 7/29/2010 6:57 AM | Add Comment

SEC Awards $1 Million Bounty to Insider Trading Informant

Posted by Todd Cipperman at 7/26/2010 5:35 AM | Add Comment

SEC Adopts New ADV Part II: Extensive Disclosure and Publicly Available

Posted by Todd Cipperman at 7/22/2010 5:18 AM | Add Comment

SEC Argues that SOX Protects Third-Party Whistleblowers

Posted by Todd Cipperman at 7/21/2010 5:58 AM | Add Comment

Dodd-Frank Requires Short Sale Reporting and Prohibits Manipulative Shorts

Posted by Todd Cipperman at 7/20/2010 5:53 AM | Add Comment

Schapiro Outlines SEC’s Agenda Following Passage of Financial Reform

Posted by Todd Cipperman at 7/12/2010 7:04 AM | Add Comment
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