SEC Enforcement Priorities as a Guide for Investment Adviser Policies and Procedures

SEC regulations require investment advisers to put into place policies and procedures that are reasonably designed to prevent violations of the securities laws and SEC rules. Reviewing enforcement trends is a helpful way to test for weak spots in existing policies and procedures, to learn from the pitfalls that have ensnared others, to think critically about the risks inherent in a particular adviser’s business model and to be best situated for your next exam. In this chaper for Globe Law and Business’ Hedge Funds: A Practical Global Handbook to the Law and Regulation, partners Charles Clark, Craig Warkol and Peter White and associate Noah Gillespie discuss the SEC’s enforcement priorities with respect to investment adviser policies and procedures.