In the past year there have been eight general types of SEC Enforcement actions:
- Failure to Adopt and Implement Cybsersecurity Policies and Procedures
- Inadequate Review of Investment Advisory Agreements
- Omissions and Misrepresentations Regarding the Nature of Client Investments
- Improper Handling of Client Assets
- Misrepresentations Regarding Investment Risks
- Omissions and Misrepresentations Regarding a Performance, AUM, and/or the Adviser’s Background and Disciplinary History
- Delayed Response to the Discovery of Trade Errors
- Inadequate Compliance Procedures or Compliance Resources
