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The weekly news source for investment management legal and compliance professionals

News September 17, 2018 Issue

Product Decisions Without Promised Internal Review May Lead to SEC Sanctions

Donít fall into the trap of adding or dropping investment products to satisfy clients or business affiliates without conducting the internal reviews promised in Form ADV and marketing materials. Such actions may at the time seem like a way to keep key stakeholders happy, but it is a recipe for an SEC investigation and possible enforcement action.

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