Catherine Anderson

Catherine Anderson

Foley Hoag LLP

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Latest Publications


Impact of New European AIFMD Regulation on SBICs

The recent adoption of the European Alternative Investment Fund Managers Directive (AIFMD), effective July 2013 (and with transitional provisions in some countries through 2014), has imposed complex new regulations on most...more

10/14/2015 - AIFMD Disclosure EU Filing Requirements Fund Managers Investors Marketing Notifications Registration SBIC

Bureau of Economic Analysis (BEA) Issues New Form BE-180 for U.S. Financial Services Providers Including Investment Advisers

Now that the dust has settled a little on the BE-10 benchmark survey responses, U.S. financial service providers, including investment advisers, should take note that the U.S. Bureau of Economic Analysis (the “BEA”) has...more

9/30/2015 - BE-180 BEA Benchmarks Civil Monetary Penalty Filing Deadlines Financial Institutions Form BE-10 Form BE-13 Investment Adviser Offshore Funds Reporting Requirements Surveys Time Extensions

OCIE’s 2015 Cybersecurity Examination Initiative

Second Round of Cybersecurity Examinations to Begin - On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing a...more

9/21/2015 - Broker-Dealer CISO Cyber Attacks Cyber Incident Reporting Cyber Insurance Cyber Threats Cybersecurity Data Breach Data Breach Plans Data Privacy Data Protection Data Security Investment Adviser OCIE Risk Alert SEC Security Risk Assessments Third-Party Training

Bureau of Economic Analysis (BEA) Form BE-10 August 31, 2015 Deadline Approaching

For those clients that received extensions on the filing deadline for their BE-10 surveys, they are reminded that the August 31, 2015 deadline is approaching. The BE-10 is the five year benchmark survey of United States...more

8/25/2015 - Benchmarks Bureau of Economic Analysis Filing Deadlines Foreign Direct Investment Form BE-10 Form BE-13 Investment Surveys

AIFMD: ESMA Recommends the First Wave of Non-EU Countries to Obtain a Europe-Wide Marketing Passport

On July 30, 2015, the European Securities and Markets Authority (ESMA) released its advice to the European Parliament, Council of the European Union and the European Commission on the application of the passport to non-EU...more

8/5/2015 - AIF AIFM AIFMD ESMA EU EU Council of Ministers European Commission Hong Kong Investor Protection Investors Marketing Singapore Switzerland

Bureau of Economic Analysis (BEA) Form BE-10: Industry Concern Voiced and Extension Updates

On June 8, 2015, a joint letter was sent to the U.S. Department of Commerce Secretary Penny Pritzker raising broad concerns with the Form BE-10 survey, including requirements for consolidation, burden of reporting, need for...more

6/15/2015 - Foreign Investment Form BE-10 Private Funds U.S. Commerce Department

Bureau of Economic Analysis (BEA) Form BE-10 Extension Until June 30, 2015

The BEA has posted on its website that the filing deadline for all “new filers” for the BE-10 (which is the five year benchmark survey of United States direct investment abroad) has been extended to June 30, 2015. A new filer...more

6/2/2015 - BEA Foreign Investment Form BE-10

Updated Filing Requirements in Connection with U.S. Inbound and Outbound Investment

Bureau of Economic Analysis Forms BE-13 and BE-10 - Companies should take note that the U.S. Bureau of Economic Analysis (BEA) has announced two updated filing requirements relating to cross-border investment: BE-13...more

5/13/2015 - BEA Cross-Border Transactions Filing Requirements Foreign Direct Investment Foreign Investment

SEC Issues Cybersecurity Guidance Update for Investment Advisers

On April 28, 2015, the SEC’s Division of Investment Management (the “Division”) issued a Guidance Update regarding the SEC’s initiative to assess cybersecurity preparedness and threats in the securities industry, further...more

4/30/2015 - Compliance Cybersecurity Data Protection Investment Adviser SEC

Massachusetts Conducting Cybersecurity Practices Survey of Massachusetts-Registered Investment Advisers

On June 3, 2014, the Massachusetts Securities Division released a survey to assess cybersecurity readiness and practices of Massachusetts-registered investment advisers....more

6/19/2014 - Cybersecurity Investment Adviser Privacy Concerns Risk Assessment

SEC Issues Risk Alert on Cybersecurity Initiative for Investment Advisers

On April 15, 2014, the Office of Compliance Inspections and Examinations of the Securities and Exchange Commission (the “SEC”) issued a Risk Alert regarding the SEC’s initiative to assess cybersecurity preparedness and...more

4/24/2014 - Cybersecurity Data Protection Enforcement Actions Investment Adviser SEC

Policy Statement Released Concerning the Custody Rule for Massachusetts-Registered Investment Advisers

In light of custody-related deficiencies identified by the Massachusetts Securities Division in recent examinations of Massachusetts-registered investment advisers, the Division released a Policy Statement on November 14,...more

12/11/2013 - Compliance Custody Rule Investment Adviser Verification Requirements

Reminder -- Compliance Date for Identity Theft Red Flags Rules is November 20, 2013

As a reminder, the Identity Theft Red Flags Rules jointly adopted by the SEC and CFTC, which took effect on May 20, 2013, have an upcoming compliance date of November 20, 2013. Under these rules, certain SEC and...more

10/29/2013 - CFTC Compliance Identity Theft Red Flags Rule SEC

SEC and CFTC Jointly Adopt Identity Theft Red Flags Rules Applicable to Investment Advisers and Others

Regulation S-ID - On April 10, 2013, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly adopted identity theft red flags rules (the Rules) and corresponding...more

5/29/2013 - CFTC Compliance Dodd-Frank Identity Theft Investment Adviser Red Flags Rule SEC

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