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ARTICLE · 18 NOVEMBER 2024

SEC Trends - November 2024

Gesmer Updegrove LLP
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As the Securities and Exchange Commission (SEC) continues to evolve its examination and enforcement priorities, fund managers are increasingly in the spotlight.

United StatesTechnology
Braeden Anderson
Braeden Anderson

As the Securities and Exchange Commission (SEC) continues to evolve its examination and enforcement priorities, fund managers are increasingly in the spotlight. The SEC's National Examination Program plays a critical role in promoting compliance, reducing fraud risk, and informing regulatory policy—all while serving as a key source of enforcement referrals. With these trends in mind, fund managers must be vigilant and prepared. Here's what to watch for in 2024 and beyond.

1. ESG Compliance: Moving Beyond the Hype

The SEC has normalized questions around Environmental, Social, and Governance (ESG) issues during exams. While the initial wave of ESG enforcement has subsided, the topic remains a core part of the regulatory landscape. Fund managers should ensure that ESG claims in marketing materials are consistent with actual practices to avoid allegations of greenwashing. Integrating ESG considerations into routine compliance programs, rather than relying

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