Jeffrey D. Collins

Jeffrey D. Collins

Foley Hoag LLP

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SEC Issues Notice of Intent to Increase Performance Fee Thresholds

On May 24, 2016, the Securities and Exchange Commission published in the Federal Register a notice of the Commission’s intent to issue an order (the “Proposed Order”) amending SEC Rule 205-3 (the “Performance Fee Rule”) under...more

5/26/2016 - Federal Register Fund Managers Investment Adviser Investment Advisers Act of 1940 Performance Fee Rule Private Funds Proposed Amendments SEC

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

Investment Advisers - Annual Compliance Reviews: All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their...more

1/23/2016 - AIFMD CFTC Commodities Confidentiality Agreements CPOs EU FATCA Financial Statements FINRA Form ADV Form PF Hedge Funds NFA Pay-To-Play Popular Privacy Policy Registered Investment Advisors SEC Swaps

SEC to Recommend Additional Compliance Rules for Investment Advisers

David W. Grim, Director of the SEC’s Division of Investment Management (the “Division”), recently noted in testimony before a U.S. House of Representatives subcommittee that the Division is developing new rule recommendations...more

11/10/2015 - Compliance Derivatives Dodd-Frank Registered Investment Advisors SEC Third-Party

FinCEN Proposed AML Rule For Investment Advisers

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more

9/11/2015 - Anti-Money Laundering Bank Secrecy Act CIP Comment Period Currency Transaction Reports (CTR) Financial Institutions FinCEN Internal Controls Investment Adviser Policies and Procedures Proposed Regulation Recordkeeping Requirements Reporting Requirements SEC Suspicious Activity Reports Training

SEC Division of Investment Management Issues Guidance on Personal Trade Reporting of Accounts Over Which Reporting Persons Have No...

Under Rule 204A-1 of the Investment Advisers Act of 1940, a registered investment adviser’s written code of ethics must include requirements for reporting of personal securities holdings and trading activity by the adviser’s...more

7/1/2015 - Corporate Officers Ethics Investment Adviser Investment Advisers Act of 1940 Non-Public Information SEC

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

Investment Advisers - 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...more

1/19/2015 - CPOs Filing Requirements Financial Statements Form ADV Form PF Investment Adviser SEC

SEC Issues No-Action Letter on the Definition of Knowledgeable Employee

On February 7, 2014 the staff of the Division of Investment Management of the Securities and Exchange Commission (the “SEC”) issued a no-action letter to the Managed Funds Association (the “No-Action Letter”), providing...more

3/21/2014 - Actual or Constructive Knowledge Investment Company Act of 1940 No-Action Letters SEC

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

Investment Advisers - 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...more

1/28/2014 - Commodities CPO Deadlines Financial Adviser Form 13F Investment Adviser SEC

SEC Passes Final Rules Implementing JOBS Act Amendments to Regulation D

On July 10, 2013, the SEC voted 4-1 to approve final rules, which included the adoption of new subsection (c) to SEC Rule 506 of Regulation D under the Securities Act of 1933, permitting the use of general solicitation and...more

7/12/2013 - Accredited Investors Advertising CFTC General Solicitation JOBS Act Regulation D SEC

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

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

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