BRAEDEN ANDERSON
Hi, I’m Braeden.
I'm a partner at Gesmer Updegrove LLP, where I lead the Securities Enforcement and Digital Assets practice areas. I’ve served as Assistant General Counsel at Robinhood, practiced at Kirkland & Ellis and Sidley Austin, and represented clients in high-stakes matters before the SEC, DOJ, FINRA, and state regulators.
I write and make content for people who don’t have time to guess: founders, lawyers, regulators, and smart operators who know better than to rely on Google or the AI answer without context.
I've been recognized by U.S. Best Lawyers: Ones to Watch® for Financial Services and Securities Regulation, and listed in Marquis Who’s Who in America for contributions to law and public service.
Enjoy the content. I hope you find what you’re looking for. And if you want to talk something through, don’t hesitate to reach out. I’d love to hear from you. It’s really cool when readers become clients.
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Heightened SEC Scrutiny: Investment Advisers' MNPI Policies Under the Microscope
The Securities and Exchange Commission (SEC) is intensifying its scrutiny of investment advisers’ compliance programs, particularly concerning policies and procedures designed to prevent the misuse of material nonpublic information (MNPI). Recent enforcement actions reveal that even well-intentioned but inadequately tailored policies can fall short of regulatory expectations, underscoring the importance of aligning compliance efforts with the unique risks of an adviser’s business activities.
SEC Trends - November 2024
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.
Under the Radar: SEC Penalizes Adviser for Weak MNPI Controls in CLO Trades
Managing MNPI risk is no longer just about avoiding direct trades on inside information; it’s about creating robust, tailored safeguards that address the way MNPI can impact related investments, particularly in intricate vehicles like CLOs. With the SEC placing renewed focus on MNPI in credit markets, now is the time to ensure your compliance protocols are more than just routine. This article unpacks the SEC’s action against Sound Point and provides essential takeaways for investment advisers on avoiding similar pitfalls.
Recent SEC Enforcement Action Highlights the Importance of Robust MNPI Policies in CLO Trading
In a significant enforcement action, the U.S. Securities and Exchange Commission (SEC) has sanctioned a private fund manager for failing to implement adequate policies and procedures to prevent the misuse of material nonpublic information (MNPI) while trading securities issued by collateralized loan obligation vehicles (CLOs). This case underscores the SEC’s focus on credit managers and emphasizes the importance of strong compliance frameworks for preventing MNPI violations in CLO trading.