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.
There are a number of compliance deadlines that are already set for 2025. Similarly, the 2025 Exam Priorities published by the Division of Examinations and published observations from the commission will continue to be a guide for effective compliance programs. Start your year off on the right foot with our 2025 Compliance Program Checklist.
On November 4, 2024, the SEC Division of Examinations (the “Division”) published a Risk Alert to describe the examination process for advisers of mutual funds, ETFs, and other registered investment companies (“RICs” or “funds”); the selection and scope of such examinations; and observations on core focus areas for RICs, The alert also shares a list of the typical documents and information requested during such examinations.
On September 9, 2024, the Securities and Exchange Commission (“SEC”) announced settled charges againstnine registered investment advisers for violations of Rule 206(4)-1 under the Investment Advisers Act of 1940(the “Marketing Rule”)
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.