WRITING | CONSULTING | EDUCATING | SPEAKING 

Policy Patty Toolkit 
 

Making the world a little more compliant one toolkit at a time.

Blog

The Deerfield Settlement - Advisers Should Take Notice

Posted on October 17, 2017 at 11:30 AM

The recent SEC settlement involving Deerfield Management Company L.P. (“Deerfield”), a hedge fund and registered investment adviser, raises some interesting issues around the scope of an investment adviser’s duty to create and enforce policies and procedures. Deerfield paid approximately $4.6 million to settle SEC charges that it failed to create and enforce controls reasonably designed to prevent the misuse of material, nonpublic information in violation of Section 204A of ...

Read Full Post »