SEC Issues Risk Alert Regarding Solicitor Arrangements


Recently the Securities and Exchange Commission (“SEC”) released a Risk Alert identifying the most common deficiencies found in third-party solicitor arrangements: Risk Alert. The SEC’s findings and observations are based on adviser examinations completed over the past three years. Rule 206(4)-3 (the “Solicitor Rule”) prohibits registered investment advisers (“advisers”) from...

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Overly Complicated Marketing Materials May Not Reach Their Targeted Audience

its complicated

It’s Complicated. It’s Way Too Complicated. The 2009 romantic comedy, It’s Complicated, is a humorous look at relationships. The relationship between Registered Investment Advisers (“RIAs”) and prospective clients is often made more complicated than it needs to be. I have found that some RIAs’ marketing materials are exceedingly complicated. They...

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SEC Enforcement – $12 million against Citi dark pool

dark pool

SEC Actions: In September 2018, the SEC found that: Citigroup violated an antifraud provision of the federal securities laws and that Citi Order Routing and Execution (“CORE”) failed to register as an exchange.  Without admitting or denying the findings, Citigroup and CORE have agreed to be censured.  Citigroup will pay disgorgement...

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SEC Enforcement – Private Fund Custody Audit Alert

private fund custody audit

SEC Action: In July 2018, the SEC instituted administrative cease and desist proceedings resulting in a censure and a fine of $75,000 against New Silk Route Advisors, L.P. (“NSR”) for failing to send annual audited financials to its private fund investors within 120 days of its fiscal year end.[1] Background:...

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