Although certain enforcement priorities of the U.S. Securities and Exchange Commission (SEC) have shifted under new Chairman Paul S. Atkins, the SEC continues to scrutinize investment advisers’ disclosures regarding the fees charged to their clients. A recent case filed on June 2, 2025, SEC v. Nagler, illustrates that the SEC’s Division of Enforcement continues to police this area to ensure that fees and potential conflicts of interest are disclosed accurately.

Overview

The SEC sued David Nagler and his advisory firm, New Line Capital, LLC, under the antifraud provisions of the Investment Advisers Act of 1940. As alleged in the complaint, New Line was an investment adviser with assets under management (AUM) of nearly $30 million. Nagler was the founder, owner, and chief compliance office

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