It was great to come across an article from 2007 that I co-authored with Kevin Harnish and Michael Umayam. The article takes a look at how the SEC investigates and pursues potential enforcement cases, with an emphasis on private funds and their managers. The article has aged well, and the SEC approach remains largely intact.

We wrote the article during our time at Fried Frank where Kevin and I were partners and Michael was an associate. Both Kevin and I had previously worked in the SEC’s Enforcement Division. Kevin now heads the Regulation, Investigations, Securities and Compliance Practice at Norton Rose, and Michael serves as the Chief Compliance Officer at Carlson Capital.

The article appeared in a former publication by the Managed Funds Association called the MFA Reporter. Here is a link to the article.

~ Terrance O’Malley