Author: Ronald Minsky

The Securities and Exchange Commission (SEC) announced charges against 26 broker-dealers, investment advisers, and dually-registered firms for widespread and longstanding failures to maintain and preserve electronic communications. The firms admitted to the violations, agreed to pay combined civil penalties of $392.75 million, and have begun implementing improved compliance policies and… Continue reading →

New Rule 14Ad-1 takes effect on July 1, 2024, with filing of Form N-PX due on August 31, 2024, for votes during the July 1, 2023 to June 30, 2024 reporting period. The Rule requires all institutional investment managers that are 13F filers to report say-on-pay votes on the new… Continue reading →

On April 3, 2024, the U.S. Department of Labor (DOL) published a final amendment to Prohibited Transaction Class Exemption 84-14. The amendment will become effective June 17, 2024. Registered investment advisers that manage accounts that are considered “plan assets” under the Employee Retirement Income Security Act of 1974 (ERISA) and… Continue reading →

On April 12, 2024, the Securities and Exchange Commission announced settled charges against five registered investment advisers for violations of the Marketing Rule. The firms have agreed to settle and pay a combined $200,000 in penalties, as well as cease and desist from violating the charged provisions, and to implement… Continue reading →

New Rule 14Ad-1 requires all institutional investment managers (i.e., including registered investment advisers that manage client assets-see below) that are 13F filers to report say-on-pay votes on the new version of Form N-PX when voting on the approval of executive compensation, including, but not limited to, “golden parachute” compensation. The term “golden parachute” generally refers… Continue reading →

Effective July 1, 2024, New rule 14Ad-1 requires institutional investment managers that are 13F filers to report say-on-pay votes (see below) on Form N-PX when voting on the approval of executive compensation, including, but not limited to, “golden parachute” compensation in connection with a merger or acquisition, among other matters. IF you are a 13F… Continue reading →