Policy Patty Toolkit 

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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 ...

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