Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 06 AUGUST 2014

A Compilation Of Enforcement And Non-Enforcement Actions

Foley & Lardner LLP
Explore more from Foley & Lardner LLP

Various persons have proposed that a user fee be imposed on SEC registered investment advisers in order to fund a more extensive examination program.

United StatesFinance and Banking
Peter Fetzer
Peter Fetzer
Author LinkedIn connections

Non-Enforcement

  • Renewed Call for Investment Adviser User Fees
  • OCIE Director Repeats Concerns About Compliance Issues Found During Private Equity Adviser Exams
  • Will SEC Stick to Its Guns on Reg. A Plus Regulatory Authority?
  • Mutual Funds and Advisers Should Evaluate Oversight of Proxy Advisory Firms

Enforcement

  • Misusing Client Assets Results in Sanctions Against a Registered Investment Adviser

Non-Enforcement

Renewed Call for Investment Adviser User Fees

As we reported in previous editions of our Investment Management Newsletter, various persons have proposed that a user fee be imposed on SEC registered investment advisers in order to fund a more extensive examination program by the SEC.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
United StatesFinance and Banking
Proskauer Rose LLP
Proskauer Rose LLP
Article

SEC Proposes Rule Amendments To Expand Retail Access To Private Markets

The SEC has proposed sweeping amendments to expand retail investor access to private market strategies, including changes to performance-based compensation rules for registered investment advisers and modernization of the interval fund framework. The proposals also explore new credential-based pathways for individuals to qualify as accredited investors, potentially opening private offerings to a broader pool of eligible participants.
United StatesFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

SEC Approves FINRA’s New “Outside Activities” Rule

The Securities and Exchange Commission has approved FINRA Rule 3290, which will replace existing rules governing outside business activities and private securities transactions for registered persons. This new rule narrows the scope to focus on investment-related activities while maintaining similar supervisory obligations for member firms. Understanding the key changes and implementation requirements will be critical for broker-dealers as they update their compliance policies and procedures.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

New NYSE Delisting Rules: What Microcap Companies Need To Know About The $0.25 Minimum Trading Price

The SEC has approved new NYSE and NYSE American listing rules establishing a $0.25 minimum trading price, effective July 1, 2027. A single closing price below this threshold triggers immediate trading suspension and delisting proceedings with no cure period. Companies trading at low share prices must act now during the transition period to implement reverse stock splits and establish monitoring procedures before this hard floor takes effect.
United StatesFinance and Banking
Bevilacqua
Bevilacqua
Article

The Financing Problem Behind the AI Infrastructure Boom: What Lenders and Sponsors Need to Watch

As AI infrastructure spending surges toward $697 billion in 2026, hyperscalers and compute providers are increasingly turning to debt, structured financing, and GPU-backed collateral to fund expansion. While demand projections remain bullish, a critical timing gap is emerging between capital deployment and cash flow generation, creating significant risks for lenders, sponsors, and operators across the ecosystem.
United StatesFinance and Banking
Riveron
Riveron
Article

Texas Governor Abbott Directs TCEQ To Freeze All Data Center Permits In A Whole-of-Government Action

Governor Greg Abbott has ordered the Texas Commission on Environmental Quality to immediately halt all environmental permits for data center projects, expanding a statewide regulatory freeze that now encompasses power, water, and environmental approvals. This directive establishes strict operational mandates requiring data centers to fully fund infrastructure costs, report all resource consumption...
United StatesEnvironment
Foley & Lardner LLP
Foley & Lardner LLP
Article

California Enacts Seven Data Center Bills, Effective January 1, 2027: New Tariff, Entitlement, And Disclosure Rules For Hyperscalers, Developers, And Power Producers

California Governor Newsom signed seven data center bills into law on September 21, 2026, establishing a comprehensive regulatory framework that takes effect January 1, 2027. These bills create new tariff regimes administered by the California Public Utilities Commission, impose extensive reporting requirements on data center operators, and establish water disclosure mandates and CEQA treatment protocols.
United StatesEnergy and Natural Resources
Foley & Lardner LLP
Foley & Lardner LLP
Article

More Rigs Than A Year Ago, Higher Costs, And Service Prices That Haven’t Caught Up

Oilfield service firms responding to the Dallas Fed Energy Survey for the third quarter of 2026 reported substantially broader increases in input costs than in the prices they received. The input-cost index was 60.4, compared with a prices-received index of 16.3. Each index represents the percentage of respondents reporting an increase minus the percentage reporting a decrease.
United StatesEnergy and Natural Resources
Foley & Lardner LLP
Foley & Lardner LLP
Article

Diesel Stocks Are Expected To Fall Below 100 Million Barrels. Check Your Fuel Clauses.

Diesel prices have shattered records, hitting $6.529 per gallon nationally while distillate inventories plunge below five-year lows and are expected to remain there through most of 2027. With crack spreads exceeding $106 per barrel and global supply disruptions intensifying, fleet operators and oilfield services companies face mounting fuel costs that many existing contracts weren't designed to handle.
United StatesEnergy and Natural Resources
Foley & Lardner LLP
Foley & Lardner LLP
Article

Texas Escalates Data Center Oversight With Attorney General Water-Use Investigation

Texas has launched a sweeping investigation into hundreds of data center developments that failed to comply with mandatory water use surveys, marking the latest escalation in a seven-week regulatory crackdown. The state's actions have frozen permits, paused interconnection studies, and exposed projects to criminal and civil enforcement, all while the industry faces mounting scrutiny over its rapidly growing demands on electricity and water infrastructure. With multiple state agencies now coordinating enforc
United StatesEnergy and Natural Resources
Foley & Lardner LLP
Foley & Lardner LLP
Article

Oil Is Near $90 And Gas Is Near $3. Same Wells, Different Markets.

Associated gas production in the Permian Basin continues to surge alongside oil drilling, but natural gas prices have diverged sharply from crude oil, creating significant challenges for contracts written under different price assumptions. With Henry Hub futures trading around $3 per million Btu while WTI crude hovers near $90 per barrel, operators and service companies face difficult questions about pricing mechanisms, curtailment rights, and minimum volume commitments that may no longer reflect current
United StatesEnergy and Natural Resources
Foley & Lardner LLP
Foley & Lardner LLP