United States:
Whistleblower Alert – OCIE To Examine Registered Investment Advisers For Overbroad Confidentiality Or Severance Agreements
04 November 2016
Proskauer Rose LLP
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The SEC's Office of Compliance Inspections and Examinations
(OCIE) recently published a risk alert noting that the SEC exam staff intends
to examine registrants' compliance with the Dodd-Frank
Act's whistleblower provisions. OCIE intends to examine
registered advisers for compliance, in light of recent enforcement
cases the SEC has filed based on violations of the Dodd-Frank
whistleblower rules resulting from confidentiality or severance
agreements.
Please see Proskauer's client alert OCIE Staff to Examine Registered Advisers'
Policies and Agreements for Whistleblower Rule Compliance to
read more about:
- the type of documents that SEC examiners might request,
- what the exam staff is looking for, and
- what kinds of remedial actions are at stake.
Whistleblower Alert – OCIE To Examine Registered Investment
Advisers For Overbroad Confidentiality Or Severance
Agreements
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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