Disclosure Archives

SEC Proposes Rules on Advisers’ Use of Technology

On Wednesday, the SEC proposed rules addressing conflicts of interest associated with the use of predictive data analytics by advisers and broker-dealers in investor interactions.

July 27, 2023

Tags: Conflicts of Interest, Disclosure, Technology

Considerations When Drafting an ESG 80% Policy

Coordination of disclosure, compliance, and marketing is critical when developing an ESG 80% Policy. Here are five potential approaches from K&L Gates to make it work.

February 14, 2022

Tags: Columns, Compliance, Compliance Policies, Disclosure, ESG, Gary Gensler, Names Rule

SEC Staff Releases Additional Form CRS Observations

Following a new review, SEC staff has released additional observations regarding the content, format, and web posting of Form CRS disclosures.

December 21, 2021

Tags: Discl, Disclosure, Fiduciary, Form CRS

SEC Fines PE Fund Adviser $4.5 Million in Connection with Fee Calculations

The SEC has fined an adviser to private equity funds $4.5 million for not offsetting management fees as discussed in fund disclosures.

December 21, 2021

Tags: Disclosure, Fees and Expenses, Private Equity, SEC Enforcement

The Time Has Come to Move Away from a Regulatory Preference for Paper Delivery

The Time Has Come to Move Away from a Regulatory Preference for Paper Delivery September 22, 2020 Gail BernsteinIAA General Counsel The COVID-19 pandemic has proven to be a great...

September 22, 2020

Tags: Columns, Disclosure, E-Delivery, From the General Counsel, Gail Bernstein

Adviser, Principals Fined for Charging Clients Fees Without Providing Advice

One Principal Barred for Three Years from Acting as Chief Compliance Officer A Michigan-based investment adviser and two of its principals are paying more than $900,000 to settle SEC charges...

October 05, 2021

Tags: Conflicts of Interest, Disclosure, Fees and Expenses, Fiduciary, SEC Enforcement

Private Fund Placement Agent Fined for Custody Rule Violations and Lack of Disclosure of Misappropriation

The SEC has fined an Ohio-based dual-registrant for violating the Custody Rule because the firm did not provide investors in two private funds that it advised with audited financial statements...

September 22, 2021

Tags: Custody, Disclosure, Private Funds, SEC Enforcement

CFA Institute Publishes Exposure Draft on Verification Procedures for ESG Disclosure Standards for Investment Products

The CFA Institute (CFA) has published an exposure draft outlining proposed verification procedures for its Environmental, Social, and Governance (ESG) Disclosure Standards for Investment Products (the Standards) and requests comments...

September 22, 2021

Tags: Disclosure, ESG

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