SEC Actions Against Investment Advisers In 2016: Part 3

By Jon Eisenberg, K&L Gates LLP (December 20, 2016, 1:11 PM EST) -- This is the final installment in our three-part series discussing the U.S. Securities and Exchange Commission's enforcement actions against investment advisers in 2016. In the prior two installments, we covered enforcement actions in 12 categories. In this installment, we cover enforcement actions against investment advisers involving custody violations, safeguarding client information, business continuity, Foreign Corrupt Practices Act violations, and firm procedures and individual supervision. We then include a checklist of questions that advisers may wish to consider about their practices, and we conclude with a few brief observations about the enforcement program and an educated guess about the program under a new administration....

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