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Dollar Threshold Change for “Qualified Client” Definition under the Investment Advisers Act

Most 3(c)(1) private equity and hedge funds are impacted; exempt venture capital funds are not impacted. Effective August 16, 2021, the dollar thresholds specified in the definition of “qualified client” under Rule 205-3...more

Mitigation of Investment Adviser Business Interruption and Regulatory Noncompliance Risks Related to COVID-19—Update

UPDATE: Since the publication of our Investment Adviser Alert, the staff of the SEC Division of Investment Management has issued several new and updated responses to Coronavirus (COVID-19) FAQs, expanding on prior guidance...more

Mitigation of Investment Adviser Business Interruption and Regulatory Non-Compliance Risks Related to COVID-19

The SEC and CFTC grant conditional filing extensions as firms address business continuity and risks related to the pandemic. Conditional filing extensions are available to investment advisers and certain registered funds if...more

Registration and Compliance Obligations are Reality for Private Funds in the Cayman Islands

New law imposes registration and compliance obligations on private funds that carry on business in or from the Cayman Islands. Absent an exemption, all private funds that carry on business in or from the Cayman Islands will...more

New Law Mandates Disclosure of Alternative Fund Fees By California Public Pensions

To increase the transparency of fees and expenses paid to alternative funds, every California public pension plan must require each alternative fund in which they invest to make various disclosures, and California public...more

Spoofing Is No Joke: Prosecutors Clamp Down on High-Frequency Traders

On November 3, 2015, an Illinois federal jury convicted Michael Coscia, a high-frequency commodities trader, of six counts of commodities fraud and six counts of spoofing—entering a buy or sell order with the intent to cancel...more

The Dos and Don’ts of an SEC Examination

The regulatory environment for SEC-registered advisers has become more complex as the result of a more aggressive and interconnected Securities and Exchange Commission (SEC). The connecting hub within the SEC is the Office of...more

Deadline Looming for BE-10 Filing

- Mandatory reporting required by the Bureau of Economic Analysis on Form BE-10 – 2014 Benchmark Survey of U.S. Direct Investment Abroad - Investment managers, general partners, hedge funds and private equity funds are...more

New Custody Compliance Tasks for California Registered Advisers Effective April 1

The California Commissioner of Business Oversight (“Commissioner”) recently amended California’s custody rule 10 C.C.R. Section 260.237 (the “New Custody Rule”). The New Custody Rule will be effective on April 1, 2014....more

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