|5391||SEC Decisions on Revenue Sharing Disclosure - Possible Implications||30||Feb||2:00PM||3:00PM||February||Wednesday||1||2017||
Recent decisions by the SEC, on appeal from decisions of their administrative law judges, raise troubling issues for disclosure draftsmen. These decisions concerned allegations that advisers failed adequately to disclose the receipt of revenue sharing payments even though the disclosure alerted clients that the adviser “may” receive the payments and the SEC was unable to show the modest payments were material. In one case, a compliance consultant was also involved in the drafting of the disclosures. None of these factors deterred the SEC from finding the advisers liable, leading to considerable controversy. Are all potential conflicts viewed by the SEC as material, no matter how insignificant? Is disclosure that a conflict “may” exist inadequate? Is consultation with compliance consultants irrelevant to liability?
Please join Richard Marshall, Partner at Katten Muchin Rosenman LLP, as he discusses the potential implications of these controversial positions of the SEC in this presentation.This webinar will be broadcast live on Wednesday, February 1, 2017 at 2 pm (ET).
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Richard D. Marshall
Katten Muchin Rosenman LLP
Richard Marshall counsels investment companies, investment advisers, and broker-dealers on compliance issues relating to the federal securities laws. He also defends these entities and their employees in investigations by the SEC, FINRA, and state securities regulators. Previously, he worked as a branch chief in the SEC’s Division of Enforcement in Washington, DC and as senior associate regional administrator in the SEC’s New York office, where he supervised a staff of seventy that conducted inspections and enforcement investigations of investment companies and investment advisers. He is the founding editor of the Investment Lawyer, a member of the board of editors of iMoneyNet, a former board member of the National Society of Compliance Professionals, and the current chair of that organization’s investment adviser committee. He has tried numerous cases, including SEC v. Howard, in which he successfully defended the senior officer of a large broker-dealer, who was vindicated by the D.C. Court of Appeals based on reliance on advice of counsel.
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