SEC Announces Enforcement Action Regarding Failure to Disclose Conflict of Interest Created by Outside Business Activity
On April 20, the SEC announced that it had reached a settlement with a prominent investment manager regarding alleged breaches of the Firm’s fiduciary duties under the U.S. Investment Company Act of 1940 and the U.S. Investment Advisers Act of 1940, as applicable. This alert focuses on the topic of assessing, mitigating and monitoring conflicts of interest associated with outside business activities for registered investment advisers, including advisers to both registered funds and unregistered/private funds.