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The purpose of this paper is to provide a summary of the terms of a settled Securities and Exchange Commission administrative proceeding that illustrates the views of the SEC examination and enforcement staff regarding appropriate practices for investment advisers registered under the Investment Advisers Act of 1940 (the “Advisers Act”) to follow when engaging in block trades for client accounts.

The paper summarizes the SEC's findings regarding the adviser's block trade allocation practices, resulting violations, and the adviser's remedial efforts, and provides the sanctions agreed to.

The SEC's findings related primarily to the adviser's practices regarding the allocation of block trades when participating client accounts had insufficient funds to purchase their allocation.

This settlement provides an important reminder for registered investment advisers of the focus by SEC examination and enforcement staff on trade allocation practices and related record keeping and compliance program documentation.

The paper provides a practical explanation by experienced financial services lawyers.

To review SEC enforcement action taken against an adviser over: failure to grant advisory fee breakpoint discounts based on the aggregation of related accounts requested by clients and related deficiencies in the adviser’s administration of the account aggregation feature.

Review and summarize the SEC’s finding’s regarding the adviser’s advisory fee breakpoint discount program, deficiencies in the program identified in SEC examinations, resulting violations of the Investment Advisers Act and its rules, the adviser’s remedial efforts and undertakings, and the sanctions imposed.

This settlement provides an important reminder for registered investment advisers of the need to fully address deficiencies identified in SEC examinations and of the attention paid by SEC inspection staff to client fees as a core examination area.

Practical explanation from experienced financial services lawyers.

Internet-enabled commerce activities have evidently been strong in the leisure and tourism industry. The use of the Internet reveals an ever-growing market of millions of business and leisure travelers who use the Internet for travel planning purpose. As segment-based approach is an accepted tool in strategic marketing and helps understand the needs of homogeneous travel planner subpopulations, this study suggests a framework as the guideline and procedure to improve the segmentation approach. The main aim is to increase understanding of the growing Internet travel market by accurately classifying the Internet travel planners. Following the procedures methodically shown in the framework, the study conducted multiple complementary statistical techniques to cross validate statistical results found in each step. The typology of Internet travel planners was therefore identified systematically with great accuracy and validity. The typology consists of four groups of Internet travel planners: sensate, deal, defensive, and totemic. Based on the major characteristics of each group, the study also provided discussions and suggestions for the implementation of the typology to develop successful e-commerce. The findings offer academia and practitioners a paradigm for strategic marketing.

The purpose of this paper is to analyze new SEC Rule 206(4)‐8 under the Investment Advisers Act of 1940 and discuss its practical implications.

The paper describes the new rule, the types of advisers and funds to which the rule applies, examples of topics on which advisers might make statements that run afoul of the new rule, the application of the rule to both existing and potential investors, the application of the rule beyond statements made in the context of a securities transaction, and the application of the rule to any conduct that is fraudulent, deceptive, or manipulative, including negligent conduct. The paper explains that the scope of the new rule extends beyond Section 34(b) under the Investment Company Act of 1940, that the rule creates no new fiduciary duty, and that it creates no new private right of action against fund advisers.

The new rule signals that the SEC continues to focus intently on the fund activities of both registered and unregistered investment advisers, in particular with respect to their unregistered funds.

The new rule is an indicator of the SEC's enforcement intentions. Advisers should review their compliance programs, particularly as they relate to communication and other interaction with current and prospective fund investors, in light of the new rule.

The paper provides an helpful rule description and practical guidance from experienced securities lawyers.

The purpose of this paper is to examine the phenomenon of activity-based working (ABW), an office design and management system that has emerged in the past 20 years. It investigates its manifest and underlying agendas with a view to determining its degree of cost management focus and scientific management foundations.

The paper uses historical and website analysis methodologies for investigating historical office management philosophies and practices, as well as contemporary office design and management philosophies and related ABW practices and discourse. These are examined through the theoretical lenses of governmentality and impression management theories.

Despite a rhetoric of staff empowerment, ABW’s dominant agenda is overhead cost reduction and operating cost management. This reflects scientific management principles of early twentieth-century office design and management. Cost efficiencies and productivity emerge as key ABW output foci. While ABW adopters and advocates present ABW as a desirable staff satisfaction and operations facilitator, the cost agenda nonetheless commands centre stage.

Accounting research into the office and its processes is much needed. This has been largely neglected in favour of line management and factory floor costing and accountability systems. In a world dominated by service industries, the office as a centre of organisational and economic activity merits researchers’ greater attention.

Contemporary office design and functioning developments merit greater recourse to and acknowledgement of their historic roots. Then, practitioners can better design and implement systems that build on past knowledge and learnings. While such innovations as ABW may carry potential for improved organisational performance, care is needed with respect to their balancing of agendas and suitability for their institutional and cultural environments.

Organisational work has become a dominant part of social life in most economies today. Such innovations as ABW must be considered in terms of the societal culture into which they are introduced: how they reflect and adapt to that culture and what impacts they may also have on the culture itself. This includes dimensions such as organisational and self-control, as well as personal and organisational accountability.

This study presents itself as one of the very few refereed research studies of ABW currently available in the accounting, management or property research literatures. It also represents one of the very few studies of the office in the accounting research literature internationally.

This article explores the use of informal socio-cultural practices to mitigate formal institutional voids in a qualitative study of informal self-employment in Bulawayo in Zimbabwe. Informal socio-cultural values and practices such as ubuntu and indaba were observed to be making meaningful contribution to business and lives. Development of formal institutions as a consequence was not observed though. The article proposes that economic development efforts might best serve communities in sub-Saharan Africa by facilitating institutional development that converges with local socio-culturally informed practices rather than focus on attempts to absorb informal work into a homogenously understood formal institutional system.

This chapter explores two cases of small towns as creative places in the Galloway and Borders regions of Scotland. It considers and compares their cultural development, economic contributions, resilience and sustainability. The chapter uses prior works on policy, theory, and creative rural economies as conceptual framing.

The study is an empirical exploration, which used cultural observation as an interpretive method to undertake desk and field research in the two towns presented as cases, Wigtown (Scotland’s National Book Town) and Coldstream. It offers findings related to the effects of the COVID-19 pandemic on the creative sector; cultural identity branding; the roles of anchor attractions and events; policy; digital economy; and cultural inclusion or exclusion. The conclusion is that creative placemaking is a medium-to-long term activity involving community and joint entrepreneurship between stakeholders to demonstrate sustainability and resilience. However, creative places need to be or become distinctive in some respects for the ingredients and enabling factors of placemaking to combine and sustain effectively as a destination.