An SEC subpoena arrives out of the blue. The whistleblower hotline rings and a credible complaint is documented. A regulatory examination goes sideways. Events like these are at best a distraction. They can also cause reputational and other risk to your business.
Stradley Ronon’s investment management enforcement & investigations lawyers are well-versed in helping clients respond to such events.
We regularly represent investment advisers, investment companies, hedge funds, private equity funds, boards and board committees, and officers, directors, independent trustees and other individuals in connection with examinations, investigations, and enforcement actions by the SEC, Department of Justice, other federal and state regulators, FINRA and other industry self-regulatory organizations.
We also conduct internal investigations designed to assist clients in preventing or limiting the scope of potential enforcement action by identifying areas of risk and devising corrective strategies.
In each case, we partner with Stradley lawyers who work on a day-to-day basis with investment management clients and draw from a team with decades of experience at the SEC’s Enforcement and Investment Management divisions.
Some of our recent investment management enforcement & investigations representations have involved:
- Alternative Mutual Funds
- Payments to Intermediaries
- Performance Advertising and Recordkeeping
- Cross Trades and Affiliate Transactions
- Securities Lending
- Insider Trading
- Conflicts of Interests and Nondisclosures of Conflicts, Risks and Other Matters
- Trade Allocation
- Valuation Procedures
- Collateralized Debt Obligations
- Ratings Agencies
- Market Timing
- Use of Fund Assets to Pay Marketing Expenses
- Compliance With Section 19(a) of the 1940 Act’s Dividend Payment Notice Requirement