Advisory firm policies should ensure firm’s compliance program is able to efficiently identify and address any potential risks.
The SEC charged a registered real estate private equity firm with executing a transaction between two funds (“Fund I” and “Fund II”) it advised on different terms than what was disclosed to the Fund I investor advisory committee (“Fund I IAC”).
The Department of Labor has released an FAQ focused on the transition period after the June 9th implementation of the Fiduciary Rule and related prohibited transaction exemptions.