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 October 21, 2024, the SEC’s Division of Examinations (“EXAMS”) published its 2025 Examination Priorities. The SEC’s fiscal year runs from October 1st to September 30th, and this fiscal year marks the 30th anniversary of the creation of the Division of Examinations, originally established as the Office of Compliance Inspections and Examinations.
On September 3, 2024, the SEC announced charges against ClearPath Capital Partners, LLC, for failing to comply with rules governing the safekeeping of client assets and for its use of impermissible liability disclaimers in its advisory and private fund agreements.
On September 9, 2024, the SEC announced settled charges against nine registered investment advisers (“RIAs”) for violating the Marketing Rule by disseminating advertisements that included untrue or unsubstantiated statements of material fact or testimonials, endorsements, or third-party ratings that lacked required disclosures. Combined, these nine RIAs agreed to pay $1,240,000 in civil penalties.
The SEC fined Pacific Financial Group $430,000 for advertising that presented hypothetical performance. In an order issued on August 9, 2024, the SEC pointed out that Pacific Financial Group advertised hypothetical performance on its public website without implementing policies and procedures reasonably designed to ensure that the hypothetical performance was relevant to the likely financial situation and investment objectives of the intended audience.