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Memo#
35698

SEC Charges Five Investment Advisers with Marketing Rule Violations

On April 12, the SEC announced that it had charged five investment advisers[1] with violations of Rule 206(4)-1 under the Investment Advisers Act ("Marketing Rule") for "advertis[ing] hypothetical performance to the general public on their websites without adopting and implementing...
ICI Default BG
Memo#
35657

Massachusetts Court Validates Fiduciary Conduct Standard Regulations

On January 18, 2024, Robinhood Financial LLC settled charges brought by the Massachusetts Securities Division in connection with an August 2023 Massachusetts Supreme Judicial Court decision upholding a Massachusetts rule, finalized in 2020, that imposes a fiduciary duty on broker...
ICI Default BG
Memo#
35649

Wyoming Finalizes ESG Investing Rules

Parts of the rules package proposed by Wyoming Secretary of State Chuck Gray on Environmental, Social, and Governance ("ESG") investment disclosure and consent went into immediate effect on February 27, 2024 and require compliance as of that date.
ICI Default BG
Memo#
35642

SEC Adopts Amendments to Form PF

On February 8, 2024, the Securities and Exchange Commission (SEC or the "Commission") adopted amendments to Form PF, the confidential reporting form for certain registered investment advisers to private funds including those that also are registered with the Commodity Futures Trading...