Back To Basics – Private Equity Compliance – Beyond Fee And Expense Practices
Jacko Law Group, P.C. (“JLG”) wrote a Legal Tip titled Back To Basics – Private Equity Compliance – Beyond Fee And Expense Practices in October, 2016.… Read More
Legal Considerations For Your Cybersecurity Program
Michelle L. Jacko wrote a Legal Tip for Jacko Law Group titled Legal Considerations For Your Cybersecurity Program in August, 2016.… Read More
Regulatory Requirements And Risks Associated With Conducting Due Diligence On Third-Party Service Providers
The Legal Tip for Jacko Law Group titled Regulatory Requirements And Risks Associated With Conducting Due Diligence On Third-party Service Providers was written in July, 2016.… Read More
The Distinctions Between Sub-Advisory And Third-Party Asset Manager Arrangements
The Legal Tip for Jacko Law Group titled The Distinctions Between Sub-advisory And Third-party Asset Manager Arrangements was written in August, 2014.… Read More
Pennsylvania Advisor charged with $2.5 million Fraud
Patricia S. Miller (“Miller”), a former representative of Investors Capital Corp. (“ICC”) and Janney Montgomery Scott (“Janney”), was indicted on charges of orchestrating a $2.5 million fraud of 20 clients beginning in 2002. According to the Criminal Complaint issued by…
Requirements of Rule 506(d): Bad Actors
As a continuation of last week’s entry, this blog focuses on other considerations for general solicitation under Rule 506(d) of Regulation D, including the condition that the issuer takes reasonable care to verify that each person involved in the…
Requirements of Rule 506(c): Reasonable Steps
This September, the Securities and Exchange Commission (“SEC”) modified Regulation D and created new Rule 506(c), allowing general solicitation and advertising by issuers of private funds pursuant to certain conditions. These conditions require, among other things, that issuers relying on…
Recent SEC Matter Exemplifies Importance of Proper CCO Supervision
The role of the Chief Compliance Officer (“CCO”) is to ensure that a firm complies with its outside regulatory requirements and internal policies. This requires the CCO to administer, test and supervise the policies and procedures (P&Ps) of a firm…
Recent Events Portray Importance of Conducting Proper Due Diligence Prior to Investing in Securities
Recently, the Securities and Exchange Commission (“SEC”) charged a penny stock promoter, David F. Bahr of Rancho Santa Fe, California, with fraudulently arranging the purchase of over $2.5 million worth of shares in a penny stock company in an attempt to…
Recent SEC Case Exemplifies Importance of Policies & Procedures Designed to Protect Clients and Monitor Third-Party Vendors
Recently, the Securities and Exchange Commission (SEC) brought charges against Institutional Shareholder Services Inc. (ISS), a company that advises large investors on corporate proxy issues, claiming that ISS failed to safeguard its clients’ confidential votes. Specifically, the SEC claimed that…