Rich Fagerer

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On June 20, 2014, the U.S. Securities and Exchange Commission (“SEC”) charged two U.S. private equity firms with violating obligations under the U.S. Investment Advisers Act of 1940 (“Advisers Act”) that had been adopted as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd Frank Act”). The administrative proceedings represented the first enforcement action the SEC had ever brought under the new “pay-to-play” rules of the Advisers Act, which prohibit investment advisers…