The SEC’s “broken windows” approach has already shattered private fund enforcement records. Since January, regulators have brought cases against at least 27 private fund advisers or their executives, an RCW analysis of Commission records shows. That sets a record for the Dodd-Frank era. The previous record, 18, was set in 2018 and then again in 2020. In 2012, as the Commission mopped up the mess of the Great Recession and began the still-incomplete job of implementing Dodd-Frank, there were 17 cases, Commission records show. “It’s clear that they’re scrutinizing a lot of different areas in the private fund industry,” says Greg Larkin, a Financial Industry and Private Investment Funds partner in Washington, D.C., while speaking with Regulatory Compliance Watch. “You have to readjust to the environment that you’re in. You have to be much more careful on basically everything. Conflicts. Fees and expenses. Custody rule. The marketing rule is the big flashing light to me.”