Thought Leadership

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 against Dallas-based registered investment adviser [...]

Understanding the Reg. S-P Requirements

It is one of the questions we are often asked at Salus GRC, and one which financial organizations should be [...]

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 a rule adopted by the [...]

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 a “Culture of Compliance,” highlighting [...]

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 principal nearly $1,000,000 for failing [...]

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

Have a cybersecurity incident? Investment advisers, broker-dealers, investment companies, and transfer agents included in the scope of a new SEC [...]

SEC Proposes New Anti-Money Laundering Rule for RIAs and ERAs – May 14, 2024

On May 13, 2024, the SEC proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers [...]

A Failure to Supervise Can Be a Failure to Document…

Early in April, the investment adviser population was hit with another “off-channel” enforcement action from the SEC with its $6.5 [...]

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 offerings under Regulation D, whereby [...]

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 provided EXAMS’ preliminary marketing-related observations [...]

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 against the backdrop of an [...]

The SEC Moves in on the DeFi Space with a Wells Notice for Uniswap – April 17, 2024

On April 10, the CEO of Uniswap Labs, one of the largest decentralized cryptocurrency exchanges, announced on X that Uniswap [...]

The Fox in the Henhouse – The Importance of Audit Independence in Assessing Cybersecurity Risk

It is one of the questions we are often asked at Salus GRC, and one which financial organizations should be [...]

SEC Fines Five RIAs for Marketing Rule Violations – April 15, 2024

On April 12, 2024, the SEC fined five registered investment advisers for advertising hypothetical performance on their websites in violation [...]

SEC Expands Insider Trading Scope by Prevailing in “Shadow Trading” Case – April 9, 2024

On April 5, 2024, a jury in federal court in California found a pharmaceutical executive liable for insider trading when [...]

Private Markets Fund Managers – Effective SEC Exam Preparation Strategies

Over the past few years, under the leadership of SEC chairman Gary Gensler, we have witnessed a significant increase in [...]

SEC Fines Hedge Fund Manager $6.5 Million for Electronic Communications Violations – April 4, 2024

On April 3, 2024, the SEC took a notable enforcement action against Senvest Management, LLC, a $3.6B hedge fund manager, [...]

Cybersecurity Myths and Misconceptions for Emerging Managers

Common cybersecurity myths and misconceptions, debunked by Salus GRC cyber experts.