SEC Commissioner Daniel M. Gallagher recently issued a statement explaining his rationale for casting dissenting votes in two recent SEC enforcement actions.  In his remarks, Gallagher clarified his position, argued against the SEC’s trend toward strict liability for chief compliance officers under Rule 206(4)-7 under the Advisers Act and urged the Commission to consider whether amendments to the Advisers Act or staff- or Commission-level guidance should be issued in order to avoid adverse consequences to the industry.  This article summarizes Gallagher’s statements.  For additional insight from SEC officials, see “Acting OCIE Director Discusses the Office’s Focus on Private Equity Managers and Emphasizes the Importance of Disclosure by Advisers,” Hedge Fund Law Report, Vol. 8, No. 21 (May 28, 2015); and “Conflicts Remain an Overarching Concern for the SEC’s Asset Management Unit,” Hedge Fund Law Report, Vol. 8, No. 10 (Mar. 12, 2015).