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Best of Blog Archives

While we would love to keep a record every “Our Take” Best of Blog Archives we’ve ever written, clearer heads have prevailed. What follows is a compilation of the “Best of the Best” for the past two years, by month, three entries each. Please enjoy this treasury of insights.

December 2013

  1. BD Pays $150 Million to Settle Civil and Criminal Charges for Excessive Commissions
  2. Hedge Fund to Pay Nearly $9 Million for Weak Valuation Process
  3. CEO Did Not Understand His CCO Job

November 2013

  1. SEC Charges Fund Manager and PM with Lying to Board and Compliance Failures
  2. Fund Administrator Accepts Deferred Prosecution Agreement for Turning in Client
  3. Adviser Violated Custody Rule by Pooling Assets Pending Investment

October 2013

  1. Higher Cost Share Class Violated Best Execution
  2. SEC Staff Defines Compliance vs. Supervision in FAQ
  3. SEC Will Target Gatekeepers Including Independent Directors and Auditors

September 2013

  1. Investment Bank to Pay $920 Million Because of Weak Internal Controls
  2. BD to Pay over $1.1 Million to Settle Best Execution Charges
  3. Adviser Should Have Recommended No-Load Funds

August 2013

  1. SEC Imposes New Compliance Rules on Broker-Dealers
  2. CFTC Allows Registered Funds to Rely on SEC Compliance
  3. Portfolio Manager Barred/Fined for Lying to CCO

July 2013

  1. Hedge Fund Founder/Owner Charged with Failure to Supervise PMs
  2. SEC Allows Private Fund General Solicitation with Conditions
  3. CCO Suspended for Failing to Implement Custody Checks

May 2013

  1. Fund’s Trustees and Administrator Faulted for Inadequate Compliance Program
  2. Firm to Pay $9 Million for E-Mail Compliance Failures
  3. Hedge Fund Sponsor Valued Private Company at Cost, Not Fair Value

April 2013

  1. SEC Adopts Identity Theft Red Flags Rule for Advisers, Funds, and BDs
  2. SEC Charges Adviser for Misleading GIPS Compliance Claims
  3. FINRA Allows Limited Use of Back-Tested Data for ETF Indexes

March 2013

  1. Supreme Court Says that SEC Must Bring Actions within 5 Years of Fraud
  2. SEC Says One-Third of Advisers Violate Custody Rule
  3. Private Equity Firm Failed to Verify Valuations in Pitchbook

February 2013

  1. SEC Releases Exam Priorities
  2. Fund Sponsor Sued for Failing to be Specific about Investing Risks
  3. BDs Fined $1.2 Million for Failing to Retain/Review E-mails

January 2013

  1. Federal Court Demands More Scrutiny of Adviser/Sub-Adviser Fees
  2. SEC Requires Adviser to Retain Outside Firm to Remedy Weak Compliance Program
  3. Senior SEC Enforcement Official Expects More Cases against Private Equity Firms

December 2012

  1. SEC Sues Independent Directors for Failing to Oversee Fair Valuation Process
  2. SEC Says Compliance Procedures Should Require Two Approvals to Move Client Funds
  3. Adviser Mis-Used Software to Create Hypothetical Backtested Performance