This is the first article in a four-part series covering this year’s edition of Practising Law Institute’s annual hedge fund enforcement event. Participants at the event included regulators from the SEC, CFTC and New York Attorney General’s Office, who
provided candid and detailed insight into their hedge fund enforcement priorities, principles, goals and experience. This first article discusses the key points made by Julie M. Riewe, Co-Chief of the SEC’s Asset Management Unit, with respect to enforcement trends, principal transactions, conflicts raised by side-by-side management, valuation, allocation of expenses
and the potential deterrent value of smaller enforcement actions. The second article in this series will address CFTC enforcement concerns and cases, New York Attorney General’s Office initiatives and defense strategies for avoiding and managing government investigations. The third article in the series will focus on SEC inspections and examinations. And the final article will provide instruction (based on points made at the PLI event) on how to establish an effective private fund compliance program. See also “Top SEC Officials Discuss Hedge Fund Compliance, Examination and Enforcement Priorities at 2014 Compliance Outreach Program National Seminar (Part Three of Three)
,” Hedge Fund Law Report, Vol. 7, No. 9 (Mar. 7, 2014); “OCIE Director Andrew Bowden Identifies the Top Three Deficiencies Found in Hedge Fund Manager Presence Exams and Outlines OCIE’s Examination Priorities
,” Hedge Fund Law Report, Vol. 7, No. 38 (Oct. 10, 2014).