We have previously posted on the issue of CCO liability, a very sensitive subject, to say the least, for many readers of this blog.  If this is a subject that interests you, then there was a very intriguing development this past week in this area that merits your attention.

It came in the form of

Obviously, given the name of this blog, the focus is on broker-dealers, but we also have a robust practice advising RIAs and investment management companies.  In that vein, a group of attorneys working in our Cleveland office published a Client Alert today that discusses a recent Investment Management Guidance Update published by the SEC.

The