- A CPO will be prohibited from claiming an exemption from registration under CFTC Regulation 4.13 if it or any of its principals has in their backgrounds a statutory disqualification under the Commodity Exchange Act.
- A...more
6/12/2020
/ Bad Actors ,
Certification Requirements ,
CFTC ,
Commodity Exchange Act (CEA) ,
Commodity Pool ,
CPOs ,
Exemptions ,
Final Rules ,
Investment Management ,
National Futures Association ,
Registration Requirement ,
Securities and Exchange Commission (SEC)
Introduction -
Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals....more
10/12/2017
/ Bad Actors ,
Bureau of Economic Analysis ,
CFTC ,
Cryptocurrency ,
Custody Rule ,
Cybersecurity ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Electronic Communications ,
Employee Retirement Income Security Act (ERISA) ,
EU ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Direct Investment ,
Form ADV ,
Fund Expenses ,
GAAP ,
General Data Protection Regulation (GDPR) ,
Hedge Funds ,
Insider Trading ,
Investment Adviser ,
Investment Management ,
IRS ,
MiFID II ,
NFA ,
Pay-To-Play ,
Private Equity Funds ,
Private Funds ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Tax Audits
The staff of the SEC's Division of Corporation Finance recently published additional "Compliance and Disclosure Interpretations", starting at 260.28, relating to the bad actor disqualification in Rule 506 under the Securities...more
As discussed (see Below) , the Securities and Exchange Commission (SEC) adopted changes to Regulation D and Rule 144A, addressing general solicitation, new filing requirements and “bad actor” disqualification events (among...more