What Does the Regulatory Scheme for Financial Services Look Like?

This: Click for the full PDF file SEC Commissioner Daniel M. Gallagher drew this picture of the new rules applicable to U.S. financial services holding companies since Dodd-Frank. “The stakes here are considerable: regulatory burdens divert capital away from the real economy—this acts as a barrier to entry for new market participants and further entrenches … Read more »

Referral Fee Disclosure and Conflicts

The Securities and Exchange Commission brought another enforcement case involving an investment adviser and private funds. PageOne is a registered investment adviser that recommended three private investment funds to its clients. The SEC found serious conflicts the were not disclosed or materially misrepresented. PageOne disclosed that is was paid a “referral fee” by the private … Read more »

SEC Issues Second Exemptive Relief from Pay-to-Play

It’s been about a year since the Securities and Exchange Commission granted its first exemptive order Rule 206(4)-5 when an adviser accidentally violated the pay-to-play rule. The SEC has now issued its second relief order. Ares Real Estate Management Holdings filed for exemptive relief after a senior partner wrote a $1,100 check to Colorado Governor … Read more »