Ever since the SEC created the Asset Management Unit back in 2010, the amount of scrutiny investment advisers face has continued to intensify.  And with this intense scrutiny, the SEC is forging new ground in its regulation of investment managers.  In a guest article, Andrew Dunbar, a partner at Sidley Austin LLP, discusses the series of “firsts” in SEC enforcement actions we saw in 2014 relating to investment advisers.  These firsts included the SEC’s increasing requirement in seeking admissions, as well as actions relating to “pay to play” and fees and expenses.  Understanding these new areas of enforcement, which may develop into trends, can help investment managers navigate the 2015 enforcement climate and update their compliance programs and risk inventories appropriately.  For additional insight from Dunbar, see “How Can Hedge Fund Managers Understand Recent SEC Developments to Mitigate Enforcement Risk?,” Hedge Fund Law Report, Vol. 6, No. 8 (Feb. 21, 2013).