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Jeffrey D. Collins

Jeffrey D. Collins

Foley Hoag LLP


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Reminder: Deadline for Form PF Annual Filers is April 30, 2013

As a reminder, smaller private fund advisers registered with the SEC and “large private equity fund advisers” with a fiscal year-end of December 31 must file their Form PF with the SEC by April 30, 2013....more

4/17/2013 - Form PF Private Equity Funds Private Funds SEC

All Fund Managers Marketing in the European Union Must Take Note: First Deadline Under European Union Alternative Investment Fund...

The first compliance date under the European Union’s recently adopted Alternative Investment Fund Managers Directive (the “AIFMD”) is July 22, 2013....more

4/9/2013 - AIFMD Compliance Disclosure Requirements EU Fund Managers

DF Protocol Deadline is May 1, 2013

Managers Who Use Swaps Should Act Now - Managers of funds and separately managed accounts that use swaps are reminded that they (or their clients) must complete the DF Protocol Adherence Letter and DF Protocol...more

4/3/2013 - DF-Protocol Dodd-Frank ISDA Required Documentation Swap Dealers Swaps

Reminder: Deadline for Obtaining CFTC Interim Compliance Identifier for Parties Trading in Swaps

On March 15, 2013, the Commodity Futures Trading Commission’s Division of Market Oversight and Office of Data and Technology issued an advisory, reminding all swap market participants of the imminent deadline to comply with...more

3/22/2013 - CFTC CICIs Disclosure Requirements Recordkeeping Requirements Swaps

Reminder: Form ADV Annual Amendment Due April 1

As a reminder, all SEC-registered advisers, state-registered advisers, SEC-exempt reporting advisers and state-exempt reporting advisers with a fiscal year ending December 31, 2012 must update and file their Form ADV by April...more

3/22/2013 - Form ADV SEC

Extended Compliance Deadlines for Clearing of iTraxx CDS Indices

As a follow up to our earlier Foley Adviser, the compliance deadlines have been extended for mandatory clearing of European iTraxx credit default swap (CDS) indices. ...more

3/8/2013 - Compliance Deadlines iTraxx CDS indices

Reminder: Upcoming Deadlines for Clearing Requirements for Certain Swaps

Investment managers who use swaps on behalf of their clients (including funds) are reminded that the phase-in for mandatory clearing of certain types of swaps has begun. Investment managers should be analyzing (a) the types...more

3/5/2013 - Commodity Pool Credit Default Swaps Deadlines Derivatives Clearing Organizations ERISA Interest Rate Swaps Investment Management Swaps

CFTC 4.13(a)(3) Annual Affirmations Due by March 1st

As a reminder, fund managers relying on the exemption from registration with the U.S. Commodity Futures Trading Commission (the "CFTC") set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more

2/25/2013 - CFTC Exemptions Fund Managers Investment Adviser NFA

Massachusetts Securities Division Sending Letters Requiring Documentation from MA Exempt Reporting Advisers

The Massachusetts Securities Division ("the Division") is currently sending letters to exempt reporting advisers in Massachusetts ("MA ERAs") who manage private funds which rely on the exclusion from the definition of...more

2/1/2013 - Annual Filings Exemptions Financial Statements Investment Adviser Investment Company Act of 1940 Private Investment Funds Required Documentation Securities

Important Dates and Reminders for Investment Management Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and...

Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least annually (and best practice is...more

1/28/2013 - Compliance Financial Statements FINRA Hedge Funds Investment Adviser Privacy Policy Private Equity Funds

Recent CFTC Changes and Looming Deadlines

Investment managers who invest in futures or swaps are reminded that important registration and/or filing deadlines with the U.S. Commodity Futures Trading Commission (the “CFTC”) are quickly approaching....more

11/16/2012 - CFTC CPO Futures Swaps

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