The SEC’s move to step up enforcement actions against investment advisers is only the tip of the iceberg, according to one former SEC official. “An enforcement wave is coming,” said Jordan Thomas, a partner at Labaton Sucharow LLP and former assistant director at the Securities and Exchange Commission’s asset management unit. “The world is about to change for investment advisers.” Last week alone, three advisory firms were charged with having inadequate or nonexistent compliance programs, charges which came shortly after the agency reported that it filed a record 146 actions against investment advisers in fiscal 2011, a 30 percent increase over the previous year.

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