Enforcement

/Enforcement

SEC Takes Strict Stance on General Solicitations of Certain Regulation D Offerings

SEC Takes Strict Stance on General Solicitations of Certain Regulation D Offerings WHAT HAPPENED? In a review of a FINRA disciplinary action, the SEC affirmed its zero-tolerance policy for general solicitations of specific Regulation D offerings. The disciplinary action addressed an independent broker-dealer and investment adviser that offered interests of an [...]

CCO Charged with Inadequate Form ADV Disclosures

CCO Charged with Inadequate Form ADV Disclosures WHAT HAPPENED? On March 29, 2017, the SEC charged the dually-acting principal and Chief Compliance Officer of Alison, LLC, with failing to provide specific books and records to the Commission’s examination staff. In addition, the examination concluded that the registered investment adviser’s Form ADV failed [...]