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CFTC and SEC Issue Privacy Guidance

CFTC Proposes New Swap Data Reporting Requirements and NFA Proposes Dues Surcharge for Swap Firms - INTRODUCTION - The Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”)...more

Questions & Answers on State and Local Variations on the SEC Pay-to-Play Rule

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

Pennsylvania Treasurer Prohibition on Third-Party Placement Agents

The Treasurer of the Commonwealth of Pennsylvania has prohibited investment managers from using third-party placement agents for funds managed on behalf of the Commonwealth of Pennsylvania Treasury Department. The Treasury...more

SEC Adopts Rules for Reporting Separately Managed Accounts on Form ADV and Revised Recordkeeping Rules

Amendments to Form ADV - Information Regarding Separately Managed Accounts - The SEC’s final amendments to Part 1A of Form ADV include items intended to collect more information about each adviser’s SMAs. The...more

SEC Proposes Rules for Reporting Separately Managed Accounts on Form ADV and Revised Recordkeeping Rules

On May 20, 2015, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to Part 1A of Form ADV in three areas: to collect information regarding separately managed accounts (“SMAs”) and additional information...more

Questions & Answers on State and Local Variations on SEC Pay-to-Play Rule

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

CFTC Adopts Harmonization Rules for Investment Advisers that are Commodity Pool Operators of Registered Funds

On August 13, 2013, the Commodity Futures Trading Commission (“CFTC”) adopted long-awaited harmonization rules (“Harmonization Rules”) for operators of registered investment companies (“Registered Funds”) that are subject to...more

CFTC Extends Compliance Date for Operators of Funds of Funds

Background - At the request of the Investment Adviser Association and the Managed Funds Association, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission...more

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