Author: The Securities Compliance Team

$6.5 MILLION TEXTING PENALTY: Investment Adviser Charged by SEC for Recordkeeping Failures

By Thomas Kellerman & The Securities Compliance Team on April 5th, 2024

Posted in Investment Management & Securities

On April 3, 2024, the Securities and Exchange Commission announced charges against a registered investment adviser for recordkeeping failures regarding personal device communications and pre-clearance of securities transactions in employees’ personal accounts. The firm was charged and agreed to pay a $6.5 million dollar penalty and to implement improvements to… Continue reading

SEC Settles Charges Against Investment Advisers for Misleading AI Claims

By Thomas Kellerman & The Securities Compliance Team on March 21st, 2024

Posted in Investment Management & Securities

Background On March 18, 2024, the Securities and Exchange Commission announced settled charges against two SEC registered investment advisers for making false and misleading statements about their purported use of artificial intelligence (“AI”). The firms agreed to settle the SEC’s charges and pay $400,000 in total civil penalties. Cause of… Continue reading

Initial Form N-PX Filing Could Apply to Your Firm Even if You Don’t Vote Proxies!

By Ronald Minsky & The Securities Compliance Team on February 21st, 2024

Posted in Investment Management & Securities

New Rule 14Ad-1 requires all institutional investment managers (i.e., including registered investment advisers that manage client assets-see below) that are 13F filers to report say-on-pay votes on the new version of Form N-PX when voting on the approval of executive compensation, including, but not limited to, “golden parachute” compensation. The term “golden parachute” generally refers… Continue reading

Proposed AML Suspicious Activity Rule

By Thomas Kellerman & The Securities Compliance Team on February 16th, 2024

Posted in Investment Management & Securities

On February 13, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule to combat criminals and foreign adversaries from exploiting the U.S. financial system through investment advisers (the “FinCEN Rule”). The FinCEN Rule will add system transparency and help law enforcement identify risks from anonymous… Continue reading

Bitcoin for Investment Advisers – Integrating Bitcoin into Client Portfolios

By Joseph Antonakakis & The Securities Compliance Team on January 11th, 2024

Posted in Investment Management & Securities

The SEC approved eleven spot Bitcoin ETFs on January 10, 2024. As a result, investment advisers may be curious about whether or how to integrate Bitcoin ETFs into client portfolios. This blog is intended to provide an update on the regulatory landscape and inform advisers how to fulfill their compliance… Continue reading

California & Hawaii Adopt Investment Adviser Representative CE Requirements for 2024

By Joseph Antonakakis & The Securities Compliance Team on January 4th, 2024

Posted in Investment Management & Securities

Investment adviser representative continuing education requirements are critically important. Please read this alert carefully, as investment adviser representative registration may be at risk if you do not follow the instructions. Failure to complete the requirements may lead to representative deregistration in certain jurisdictions. In late 2020, the North American Securities… Continue reading

Bitcoin and Investment Advisers

By Joseph Antonakakis & The Securities Compliance Team on September 20th, 2023

Posted in Investment Management & Securities

Bitcoin and other Cryptocurrencies With recent developments in the regulatory, legal, and compliance landscape surrounding Bitcoin and a spot Bitcoin ETF (i.e., an ETF backed by physical Bitcoins. If the value of the digital coins backing the ETF rises, the value of the investment will generally be expected to increase),… Continue reading

What is Form N-PX? Who Must File it and When?

By Ronald Minsky & The Securities Compliance Team on August 3rd, 2023

Posted in Investment Management & Securities

Effective July 1, 2024, New rule 14Ad-1 requires institutional investment managers that are 13F filers to report say-on-pay votes (see below) on Form N-PX when voting on the approval of executive compensation, including, but not limited to, “golden parachute” compensation in connection with a merger or acquisition, among other matters. IF you are a 13F… Continue reading

Proposed FTC Rule Limiting Non-Compete Clauses

By Scott I. Unger & The Securities Compliance Team on February 7th, 2023

Posted in Employment Law, Investment Management & Securities

The Federal Trade Commission (“FTC”) is proposing a set of rules which, if passed and deemed constitutional would severely limit the use of non-compete clauses between employers and their employees. The proposed rule would, among other things, provide that it is an unfair method of competition for an employer to… Continue reading

Multiple locations to better serve your needs—

Hamilton, NJ

100 American Metro Boulevard
Hamilton, NJ 08619
Phone: 609.896.9060
Secondary phone: 800.535.3425
Fax: 609.896.0629
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Marlton, NJ

40 Lake Center, 401 NJ-73, Suite 130
Marlton, NJ 08053
Phone: 856.874.4443
Secondary phone: 888.241.7424
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Yardley, PA

777 Township Line Road, Suite 120
Yardley, PA 19067
Phone: 267.907.9600
Fax: 267.907.9659
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New York, NY

5 Pennsylvania Plaza 23rd Floor
New York, NY 10001
Phone: 800.535.3425
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Philadelphia, PA

The Bellevue 200 S Broad St #600
Philadelphia, PA 19102
Phone: 267.907.9600
Secondary phone: 800.535.3425
Fax: 215.564.6245
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Bridgeton, NJ

78 W Broad St
Bridgeton, NJ 08302
Phone: 856.874.4443
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