Top 5 SEC Enforcement Developments For February 2022

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This has been a busy month for SEC rulemaking and enforcement alike, and we examine the following questions:

• What can we glean from the recently issued proposed rules targeted at investment advisers, including advisers to private funds and institutional investment managers?
• How does the SEC propose to strengthen its whistleblower program?
• Can cooperation with the SEC mitigate adverse outcomes?
• What do the SEC's actions signal about its priorities?

1) Proposed Rule Changes on Private Fund Adviser Reporting, Cybersecurity, and Short Sales:  In February 2022, the SEC voted to propose three sets of rules that would (1) impose new disclosure requirements on private fund advisers, (2) specify cybersecurity risk management requirements for registe