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ARTICLE · 18 NOVEMBER 2022

2022 SEC Enforcement Results – Takeaways For Fund Managers

Proskauer Rose LLP
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Yesterday the SEC's Division of Enforcement announced its Enforcement Results for Fiscal Year 2022, and there are a few key takeaways for fund managers.

United StatesFinance and Banking

Yesterday the SEC's Division of Enforcement announced its Enforcement Results for Fiscal Year 2022, and there are a few key takeaways for fund managers.

  • The Commission brought 760 total enforcement actions in FY 2022, which was not a record but still a 9% increase over FY 2022. The SEC also filed 462 new standalone enforcement actions, also an increase over the prior year.
  • On disgorgement and penalties, the SEC set a record, obtaining orders and judgments for over $6.4 billion in disgorgement and penalties. Over the past decade, this figure has never exceeded $4.7 billion.
  • The SEC highlighted its actions against private fund advisers: specifically "recurring issues" involving undisclosed conflicts of interest, fees and expenses, MNPI, and other matters.

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