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Helpful Hints on What to Expect in 2021 from the SEC’s Division of Enforcement: COVID-19

While past performance cannot guarantee comparable future results, the information the U.S. Securities and Exchange Commission’s Division of Enforcement just released in its annual report for its 2020 fiscal year is a must-read for trendspotters who want to know what … Read More

Dually Registered Firms: Steps for Performing an Efficient Annual Review and Gap Analysis

In accordance with Rule 206(4)-7 of the Investment Advisers Act of 1940 (the “Act”), as amended, an investment adviser (“RIA”) registered with the Securities and Exchange Commission (“SEC”)  is required to conduct an annual compliance review to assess the adequacy … Read More

What CCOs and Compliance Departments Need to Know About the SEC’s New Definition of ‘Accredited Investor’

Not long ago, the ability to invest in private offerings in the U.S. was limited to those whose annualized income and net worth afforded a country-club lifestyle. The requirements were an average income of $200,000 for the last two years … Read More

SEC Charges Birinyi Associates, Inc. with Unfair Trade Practices and Compliance Failures

On July 31, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Connecticut-based investment adviser, Birinyi Associates, Inc. (“BA” or the “Firm”), with violations of Sections 206(2) and 206(4) and Rule 206(4)-7 thereunder (“the Compliance Rule”) of the … Read More

SEC Charges Valic Financial Advisors in Two Separate Actions with Disclosure Failures and Mutual Fund Selection Violations

On July 28, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Houston-based financial services firm, Valic Financial Advisors, Inc. (“VFA” or the “Firm”), a dually registered broker-dealer and investment adviser, in two separate actions for violations of … Read More

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