"Recent SEC Enforcement Actions Underscore the Importance of Understanding and Complying with Rule 105" by Scott Budlong and Michael Mann

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October 10, 2013

The SEC’s mid-September enforcement actions alleging Rule 105 violations, combined with the Risk Alert published by the SEC’s National Examination Program, have put hedge fund managers on notice.   The SEC believes the investment community is chronically ignoring Rule 105 and needs to be dramatically reminded of its requirements.  In this article, Richards Kibbe & Orbe LLP partners Scott Budlong and Michael Mann provide key takeaways from the SEC’s recent actions, as well as specific compliance suggestions. 

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"Don’t Get Caught Short by Rule 105: A Refresher for Hedge Fund Managers" by Scott C. Budlong and Michael D. Mann (Aug. 27, 2013)