CJ Schaible, Author at Vigilant LLC

Vigilant Compliance Newsletter | September 2023

Monthly Newsletter In September, we saw SEC Charges, new Adopted Rules, and Insights from Vigilant. Below is a brief overview of what took place in the month of […]

10 Firms Charged $79 Million for Recordkeeping Failures

SEC Releases Brief Introduction The SEC announced multiple charges on Friday, September 29th, for violations of recordkeeping requirements. The following type of Firms below were charged: 5 Broker […]

Material Misstatements Lead to SEC Charge | Marketing Rule

SEC Releases Brief Introduction The SEC remains active towards the Marketing Rule and has charged another Registered Investment Adviser (“RIA”) with violations towards it. As we reach […]

Private Equity Infrastructure RIA Charged for Breach of Duty

SEC Releases Brief Introduction Recently, the SEC charged a Private Equity Registered Investment Adviser (“RIA”) more than $1.6 Million for failures involving their fiduciary duty to Funds being managed. The RIA […]

Impact on Fund Names | SEC Adopts Rule Amendments

SEC Releases Brief Introduction On September 20th, the SEC adopted Rule enhancements to prevent misleading or deceptive Investment Fund Names. The main focus by the SEC of this new […]

Private Equity Firms Should Consider Outsourced Compliance

Vigilant Insights Brief Introduction Vigilant frequently emphasizes the importance of a proactive compliance culture. Firms that take compliance seriously can help decrease their risk of expensive regulatory fines […]

RIA Charged by the SEC for Repeat Compliance Failures

SEC Releases Brief Introduction A New York-based RIA was charged by the SEC for failing to adopt and implement written compliance policies and procedures, conduct an annual review […]

New Private Fund Rule Compliance Date

News and Alerts Effective Date Now Set for the Private Fund Rule The SEC recently adopted the new Private Fund Rule for Private Funds and Private Fund Advisers. […]

Misleading Disclosures Related to Information Barriers

SEC Releases Brief Introduction The SEC has filed charges in U.S. District Court against a Firm and their Parent Company for allegedly making materially false and misleading statements and […]

Feeling “Overwhelmed” by Marketing Review | Vigilant Solutions

Vigilant Insights Brief Introduction The SEC has recently released a Risk Alert describing the large amount of documents typically requested during SEC Examinations. With the SEC’s first enforcement action related […]

9 Marketing Rule Violations | SEC Charges

SEC Releases Brief Introduction On September 11th, the SEC announced charges against nine Registered Investment Advisers (“RIAs”) for violations of the Marketing Rule. All involved Firms had violations involving […]

Risk Alert for Investment Advisers | SEC Releases

SEC Releases Brief Introduction The SEC Division of Examinations (“Division” or “EXAMS”) recently published a Risk Alert to give additional information about the Risk-Based Approach the Division takes for selecting Registered […]