Disclosure Controls for Real Estate Sponsors: Building a Process That Can Withstand Scrutiny
In fiscal year 2025, the SEC filed 456 enforcement actions and obtained orders for monetary relief totaling $17.9 billion. The agency’s stated enforcement priorities for the coming period include offering frauds, material misrepresentations, inadequate disclosures, and breaches of fiduciary duty. Troutman Pepper’s analysis of those results identified a common thread running through the cases: alleged […]