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Articles by Ronald Minsky
More Than $390 Million in Penalties for Recordkeeping Failures | JD Supra
The Securities and Exchange Commission (SEC) announced charges against 26 broker-dealers, investment advisers, and dually-registered firms for widespread and longstanding failures to maintain and preserve electronic communications. The firms admitted to the violations, agreed to pay combined civil penalties of $392.75 million, and have begun implementing improved compliance policies and procedures.
More Than $390 Million in Penalties for Recordkeeping Failures
The Securities and Exchange Commission (SEC) announced charges against 26 broker-dealers, investment advisers, and dually-registered firms for widespread and longstanding failures to maintain and preserve electronic communications. The firms admitted to the violations, agreed to pay combined civil penalties of $392.75 million, and have begun implementing improved compliance policies and procedures.
More Than $390 Million in Penalties for Recordkeeping Failures
The Securities and Exchange Commission (SEC) announced charges against 26 broker-dealers, investment advisers, and dually-registered firms for widespread and longstanding failures to maintain and preserve electronic communications. The firms admitted to the violations, agreed to pay combined civil penalties of $392.75 million, and have begun implementing improved compliance policies and procedures.
Navigating the New Compliance Landscape: Understanding Rule 14Ad-1 and Form N-PX Filing | JD Supra
New Rule 14Ad-1 takes effect on July 1, 2024, with filing of Form N-PX due on August 31, 2024, for votes during the July 1, 2023 to June 30, 2024 reporting period. The Rule requires all institutional investment managers 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.
Navigating the New Compliance Landscape: Understanding Rule 14Ad-1 and Form N-PX Filing
New Rule 14Ad-1 takes effect on July 1, 2024, with filing of Form N-PX due on August 31, 2024, for votes during the July 1, 2023 to June 30, 2024 reporting period. The Rule requires all institutional investment managers 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.
What is Form N-PX? Who Must File it and When? | JD Supra
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.
DOL Publishes Final QPAM Exemption Amendment | JD Supra
On April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment to Prohibited Transaction Class Exemption 84-14. The amendment will become effective June 17, 2024. Registered investment advisers that manage accounts that are considered “plan assets” under the Employee Retirement Income Security Act of 1974 (ERISA) and that are subject to the ERISA prohibited transaction rules often rely on this Exemption.
Will New EPA Strategic Civil-Criminal Enforcement Policy Promote Fairness In Case Selection?
It is common when defending environmental crimes for the defense to wonder why the Environmental Protection Agency (EPA) has referred the case to the U.S. Department of Justice for criminal prosecution rather than subjecting it to the commonly used civil enforcement process.
DOL Amends QPAM Exemption, Effective June 17, 2024
On April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment to Prohibited Transaction Class Exemption 84-14. The amendment will become effective June 17, 2024. Registered investment advisers that manage accounts that are considered “plan assets” under the Employee Retirement Income Security Act of 1974 (ERISA) and that are subject to the ERISA prohibited transaction rules often rely on this Exemption.
DOL Publishes Final QPAM Exemption Amendment
On April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment to Prohibited Transaction Class Exemption 84-14. The amendment will become effective June 17, 2024. Registered investment advisers that manage accounts that are considered “plan assets” under the Employee Retirement Income Security Act of 1974 (ERISA) and that are subject to the ERISA prohibited transaction rules often rely on this Exemption.
Five Investment Advisers Charged by SEC for Marketing Rule Violations | JD Supra
On April 12, 2024, the Securities and Exchange Commission announced settled charges against five registered investment advisers for violations of the Marketing Rule. The firms have agreed to settle and pay a combined $200,000 in penalties, as well as cease and desist from violating the charged provisions, and to implement corrective actions to their compliance policies and procedures.
Five Investment Advisers Charged by SEC for Marketing Rule Violations
On April 12, 2024, the Securities and Exchange Commission announced settled charges against five registered investment advisers for violations of the Marketing Rule. The firms have agreed to settle and pay a combined $200,000 in penalties, as well as cease and desist from violating the charged provisions, and to implement corrective actions to their compliance policies and procedures.
SEC Adopts Amendments to Modernize Internet Investment Adviser Registration Exemption
On March 27, 2024, the Securities and Exchange Commission adopted amendments to modernize the rule for internet investment advisers relying on the exemption that qualifies them for SEC registration as smaller investment advisers. Investment advisers generally need to meet the assets under management threshold, advise a registered investment company, or qualify for an exemption to be registered with the SEC.
Five Investment Advisers Charged by SEC for Marketing Rule Violations
On April 12, 2024, the Securities and Exchange Commission announced settled charges against five registered investment advisers for violations of the Marketing Rule. The firms have agreed to settle and pay a combined $200,000 in penalties, as well as cease and desist from violating the charged provisions, and to implement corrective actions to their compliance policies and procedures.
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