Investment Adviser to Mutual Fund Cited for Undisclosed Conflicts
By EsqSocial Corporation 12/05/21
As proof that a little disclosure can go a long way, the SEC, on May 10, 2021, announced a settlement with an investment adviser to a registered investment company that was sanctioned for undisclosed conflicts of interest. The matter is of interest because the alleged “bad behavior” did not involve a violation of the Investment Company Act at all: no 17(a) prohibited transactions were alleged, the conduct at issue did not involve a 17(d) joint transaction and no 17(e) illegal receipt of...
By: Foley & Lardner LLP