SEC Says “Managed Accounts” May Not Provide Safe Harbor from Necessity of Monitoring Personal Securities Transactions for Investment Advisor Employees

In a release published last week, the Division of Investment Management of the SEC issued guidance on the duties of investment advisors (IAs) to monitor personal securities transactions. The SEC pointed out that while a “blind trust” does provide a safe harbor from IAs’ need to monitor personal securities activities, a traditional managed or discretionary… READ MORE

SEC Spurs Meeting of San Francisco, CA Compliance Roundtable

In Case You Missed It… On Friday, June 19, the San Francisco, California Compliance Roundtable met at the request of the SEC, who had recently finalized an enforcement action involving Sand Hill Exchange, a business operating in Silicon Valley offering security-based swaps contracts to retail investors. These activities were being conducted outside the required regulatory… READ MORE

SEC Settlements with Underwriters Begin on Municipal Continuing Disclosure Requirements

On June 18, 2015, the SEC released its first settlements with municipal securities underwriters on their continuing disclosure obligations under SEC rule 15c2-12, also known as MCDC. These come after firms self-reported violations of compliance with the rule last fall. Many municipal underwriters have been included in the SEC settlement process, but only 36 initial… READ MORE