Jay G. Baris

Jay G. Baris

Morrison & Foerster LLP

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Investment Management Legal + Regulatory Update -- October 2013

- Regulatory Updates: CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that are Commodity Pools; SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Investment...more

10/24/2013 - Audits Bad Actors Broker-Dealer CFTC Commodity Pool Compliance Continuity of Enterprises Dodd-Frank Enforcement FINRA General Solicitation Investment Adviser JOBS Act PCAOB Private Funds Rule 506 Offerings SEC

SEC to Focus on Private Fund Adviser Compliance Procedures in Rule 506(c) Offerings

With general solicitation and general advertising on the horizon, private fund advisers should review their policies and procedures to determine whether they are reasonably designed to prevent the use of fraudulent or...more

9/13/2013 - Compliance Financial Adviser FSOC Hedge Funds JOBS Act OCIE Regulation D Rule 506 Offerings SEC

Private Funds on Social Media—Proceed with Caution

When the Securities and Exchange Commission lifted the ban on general solicitation and general advertising for private offerings of securities, can marketing blitzes on Twitter and other social media sites be far behind?...more

7/16/2013 - General Solicitation JOBS Act Private Funds Private Placements Regulation D Rule 144A Rule 506 Offerings SEC Securities Social Media Twitter

Rule 156 Proposal

The SEC proposed to require private funds making Rule 506(c) offerings to file written general solicitation materials with the SEC on a temporary basis. The filings would be required to apply for a period of two years, and...more

7/16/2013 - Advertising General Solicitation Private Placements Regulation D Rule 156 Rule 506 Offerings SEC Securities Act of 1933

Goldilocks, Porridge and General Solicitation

Introduction - At long last, the U.S. Securities and Exchange Commission (SEC) took action today to implement rules that complied with the JOBS Act mandate to relax the prohibition against general solicitation in...more

7/11/2013 - Dodd-Frank General Solicitation Investor Protection JOBS Act Regulation D Rule 506 Offerings SEC Securities Act of 1933

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