November 12, 2009
Section 204A — Prevention of Misuse of Nonpublic Information
Every investment adviser subject to section 204 shall establish, maintain, and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse in violation of this Act or the Securities Exchange Act of 1934, or the rules [...]
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November 4, 2009
SEC Proposed Pay to Play Rules Draw Many Comments
Earlier this year the SEC proposed so-called “pay to play” rules which would restrict SEC registered investment advisers from managing money from state and local governments under certain circumstances. According to the SEC press release, “the measures are designed to prevent an adviser from making political [...]
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Public Comments on SEC Proposed “Pay to Play” Rules
November 4, 2009SEC Proposed Pay to Play Rules Draw Many Comments
Earlier this year the SEC proposed so-called “pay to play” rules which would restrict SEC registered investment advisers from managing money from state and local governments under certain circumstances. According to the SEC press release, “the measures are designed to prevent an adviser from making political [...]