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Abstract: 

Recent SEC enforcement actions against investment advisers and private fund managers, and an OCIE risk alert, point to subjects that are of particular concern to the Commission and the staff. The authors discuss common deficiencies alleged in the cases and identified in the risk alert. They find in these sources useful guideposts to the SEC’s continuing enforcement program and important lessons for advisers of funds.

Keywords: Misallocation of fees and expenses; excessive management fees; misuse of material non-public information

Affiliations:  1: Katten; 2: Katten.