Investment Adviser Enforcement
Our enforcement defense team draws on the insight and experience of Sidley’s market-leading Investment Funds practice in representing managers of mutual funds, registered closed-end funds, hedge funds, private equity funds, venture capital funds and separately managed accounts. We have represented our clients in every conceivable type of SEC investigation involving investment funds, including, among others, investigations related to the adequacy of disclosure of conflicts of interest; the proper calculation and allocation of fees and costs; trade allocation (cherry picking); principal trades and agency cross trades; disclosures of investment strategy, performance and assets under management; insider trading; and valuation of securities.
We also assist our investment fund clients in preparing for, and responding to, requests made by OCIE and other regulators during examinations and inspections. We consistently do so in a manner designed to best position our clients to avoid having an examination develop into an enforcement investigation.