Tag Archives: Investment Adviser


SEC Charges Firm with Pay-To-Play Violation

June 26, 2014 Dear Friends, For the first time, the SEC chargedĀ an investment adviser with violating the pay-to-play rules adopted in 2010. The firm paid an almost $300,000 fine due to $4,500 in campaign contributions made to a Philadelphia mayoral candidate and the Governor of Pennsylvania. The firm continued to accept fees from two public pension funds, within two years […]

CFTC Guidance on CPO Delegation Process

Dear Friends, On May 12, 2014, the CFTC announced a streamlined approach for considering requests for no-action relief with respect to CPOs who delegate certain activities to a registered CPO (e.g. GPs of limited partnerships who delegate CPO authority to a registered investment manager). Each delegating CPO must submit a letter certifying it meets certain criteria outlined in the release. […]

SEC Provides Guidance on Testimonials and Social Media

Dear Friends, On March 31, 2014, the SEC issued Guidance regarding Rule 206(4)-1(a)(1) of the Investment Advisers Act (“the testimonial rule”) and social media. The SEC generally prohibits client testimonials. However in its guidance, the SEC said client testimonials on independent social media sites are permissible, in certain circumstances, with the following important considerations: An investment adviser (“IA”) or investment […]