Jay G. Baris

Jay G. Baris

Morrison & Foerster LLP

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SEC Staff: Private Stock Certificates May Not Be Subject to Custody Rule

In a recent IM Guidance Update, the SEC’s Division of Investment Management said that it would not object if registered investment advisers (RIAs) to certain private funds do not maintain “private stock certificates” with a...more

8/23/2013 - Custody Rule Investment Adviser SEC Stocks

Investment Management Legal + Regulatory Update -- May 2013

In This Issue: Regulatory Updates - SEC Allows Limited Use of Social Media for Public Disclosure; Federal Reserve Board Publishes a Final Rule Specifying when Nonbank Firms are “Predominantly Engaged in...more

5/17/2013 - Broker-Dealer Custody Rule ETFs Federal Reserve Final Rules Investment Management Nonbank Firms Pensions Public Disclosure SEC Social Media Startups

SEC Adviser Exams Find Widespread Violations of Custody Rule

The SEC’s Office of Compliance Inspections and Examinations reports finding widespread compliance deficiencies related to custody of securities. In its March 4, 2013 National Exam Program Risk Alert, OCIE said that...more

3/8/2013 - Audits Custody Rule Customer Funds Protection Investment Adviser Investors NEP SEC

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