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SEC Action Highlights Need for Fund Managers with Board Seats to Display Extra Rigor in Handling Potential MNPI

June 12, 2020

On May 26, 2020, the SEC settled cease-and-desist proceedings against a fund manager stemming from alleged deficiencies in the manager’s compliance policies and procedures for handling potential material nonpublic information (“MNPI”) obtained via a portfolio investment in the debt and equity of a U.S. listed company.

In this client alert, partners Scott Budlong and Michael Mann examine the SEC settlement order and identify valuable takeaways for fund managers who are potentially exposed to portfolio company MNPI due to board representation and/or status as a lender entitled to receive confidential company information.

Click here to view the client alert.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Michael D. Mann
Partner – Washington, D.C.
Phone: +