Seward & Kissel LLP


40 Act Blog - 5 new articles


Commodities Adviser Charged with Overcharging Investors

The SEC brought an enforcement action against Equinox Fund Management LLC, an alternative fund manager based in Denver, Colorado, for overcharging...

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The SEC and FINRA Release Exam Priorities for 2016

FINRA and the SEC each released their 2016 exam priority lists.   FINRA’s list of priorities is focused on three broad themes: (1) culture,...

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SEC Issues Guidance on the Potential Application of Rule 12b-1 to Certain Sub-Accounting Fee Arrangements

On January 6, 2016, the staff of the SEC’s Division of Investment Management issued guidance (IM Guidance) about when the payment of sub-accounting...

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AML CCO Liability Case Proceeds

    The Financial Crimes Enforcement Network (FinCEN) brought a $1 million civil money penalty action against former MoneyGram Chief Compliance...

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JP Morgan Found to Have Not Disclosed Conflicts When Recommending Its Own Products

The SEC charged two J.P. Morgan wealth management subsidiaries for failing to disclose conflicts of interest to clients. J.P. Morgan has agreed to...

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