How Managers Can Navigate the Thin Line Between SEC Examinations and Enforcement

A recent Seward & Kissel program examined when and how SEC examination staff coordinate with their counterparts in enforcement; explored how advisers can navigate that dynamic; considered the pros and cons of voluntary disclosure, remediation and cooperation; and discussed the lessons from recent SEC enforcement actions. The program featured Seward partners Robert B. Van Grover and Patricia A. Poglinco, along with counsel Philip Moustakis, former Senior Counsel in the SEC Division of Enforcement. This article focuses on the key takeaways from the presentation. For further insights from Seward partners, see “ISDA 2018 U.S. Resolution Stay Protocol: Should Fund Managers Adhere or Not?” (Nov. 8, 2018); and “Study Charts Rise of Non-Equity Funds and Related Founder Share Classes” (Apr. 19, 2018).

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