Category Archives: Thought Leadership

SEC Censures Private Fund Manager for Misleading Performance Marketing

On June 14, 2024, the SEC charged a relatively small SEC-registered private fund adviser, Twenty [...]

SEC Fines Private Fund Manager Over $2 Million for Misleading Disclosures Regarding Work With Activist Short Publishers

On June 11, 2024, the SEC announced fines of over $2 million and related charges [...]

Understanding the Reg. S-P Requirements

It is one of the questions we are often asked at Salus GRC, and one [...]

U.S. Court of Appeals Vacates Private Fund Rule – June 05, 2024

On June 5, 2024, the United States Court of Appeals for the Fifth Circuit vacated [...]

The Interplay of “Proactive Compliance” and the SEC:  Take AI, for Example

Historically, the dialogue surrounding compliance among SEC regulated investment advisers has heavily focused on fostering [...]

SEC Fines Private Fund Manager $1 Million for Conflicts Disclosure and Redemption Failures – May 21, 2024

On May 14, 2024, the SEC fined a New York-based private fund manager and its [...]

SEC Adopts Incident Response Planning Rule Under Regulation S-P – May 16, 2024

On April 17, 2024, the SEC’s Division of Examinations (“EXAMS”) issued a Risk Alert which [...]

General Solicitation Under Regulation D – Recent Trends and Enforcement Activity – May 9, 2024

Over the past few years, we have seen a slow-but-steady uptick in 506(c) general solicitation [...]

SEC Issues Risk Alert on Marketing Rule Compliance – April 24, 2024

On April 17, 2024, the SEC’s Division of Examinations (“EXAMS”) issued a Risk Alert which [...]

SEC Fines Private Equity Fund Manager for Technical Violations of the Pay-to-Play Rule – April 19, 2024

On April 15, 2024, perhaps as a warning to investment advisers and their respective employees [...]