Archive:April 5, 2024

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SEC Fines Adviser for Off-Channel Communications

SEC Fines Adviser for Off-Channel Communications

By: Lance C. Dial and Pablo J. Man

On 3 April 2024 the SEC announced the first off-channel communications settlement with a registered investment adviser who was not otherwise affiliated with a broker-dealer. This settlement provides new insight into how the SEC views adviser’s recordkeeping obligations, which are narrower than broker-dealer regulatory requirements.

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