SEC Actions Against Investment Advisers In 2016: Part 2
By Jon Eisenberg, K&L Gates LLP (December 19, 2016, 11:55 AM EST) -- In this three-part series, we review the U.S. Securities and Exchange Commission's enforcement actions against investment advisers. In part 1, we reviewed enforcement actions related to (1) conflicts of interest, (2) fees and allocations of expenses, and (3) trade allocations. Today we cover (4) best execution, (5) principal trades and agency cross trades, (6) insider trading, (7) valuation of securities, (8) disclosures related to performance, assets under management, and the adviser's background, (9) failure to disclose changes in investment strategy, (10) disclosures to the SEC and to issuers rather than to clients, (11) failure to register as an investment adviser or broker-dealer, and (12) misappropriation....
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