2024 SEC Enforcement Results – Takeaways for Fund Managers


On November 22, 2024, the SEC’s Division of Enforcement announced its Enforcement Results for Fiscal Year 2024. Below are some key takeaways for fund managers:

Enforcement Actions Filed in Fiscal Years 2018 to 2024

Despite fewer total actions, the SEC has continued to actively pursue matters involving investment advisers, and SEC officials often note that private funds are a “substantive priority area” for the division. The SEC has faced considerable setbacks in the federal courts, who have rejected its aggressive slate of rulemaking affecting the private funds industry. However, the SEC still has substantial tools to identify, examine and investigate the principles it has espoused in its rulemaking—for example, focused on fiduciary obligations of private fund managers. In 2025, with a deregulatory administration in charge, rulemaking will generally be on hold, but we expect the SEC staff will continue to use its existing enforcement authority to focus on private fund manager practices. 


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National Law Review, Volume XIV, Number 339