Jeremy leads the Policy Management team, which is responsible for staying current with regulatory changes and how they impact the firm’s investment adviser clients.
On September 29, 2023, the SEC charged five broker-dealers, three dual registrants, and two affiliated investment advisors with “widespread and longstanding failures to maintain and preserve electronic communications,” according to the SEC’s press release. The ten firms will pay combined penalties of $79 million. Each firm was also censured and served a cease-and-desist order.
On September 11, 2023, the SEC announced charges against nine registered investment advisers for advertising hypothetical performance to a mass audience on their websites without meeting the requirements of the Marketing Rule. All nine firms have agreed to settle and will pay penalties ranging from $50,000 to $175,000.
On September 5, 2023, the SEC charged five investment firms who failed to comply with requirements regarding safekeeping of client assets, and/or to timely update disclosures relating to audits of financial statements for private fund’s they advise.
On September 5, 2023, the SEC charged private equity firm Prime Group Holdings LLC with “failing to disclose millions of dollars of real estate brokerage fees” that a fund managed by the firm paid to the firm’s affiliate.
On September 1, 2023, six private equity and hedge fund trade groups sued the SEC to block new private fund reforms adopted in August. The suit was filed in the Fifth Circuit Court of Appeals and argued that the SEC overstepped its statutory authority by adopting sweeping changes with these new rules for private funds.
The Department of Labor (DOL) voluntarily dismissed its appeal of the district court decision that struck down the DOL’s fiduciary reinterpretation of fiduciary status for advisers making rollover recommendations to retirement investors.
On May 3, 2023, the U.S. Securities and Exchange Commission (SEC) announced the adoption of amendments to the Form PF. This rule will impact all Form PF Large filers and all Form PF filers who manage private equity (PE) funds.