Latest Publications


"SEC Provides Custody Rule Relief for Privately Offered Securities"

On August 1, 2013, the Division of Investment Management of the Securities and Exchange Commission published an IM Guidance Update (the “Update”) regarding Rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act...more

8/22/2013 - Audits Custody Rule GAAP Investment Advisers Act of 1940 Pooled Investment Vehicles Private Offerings SEC Securities

"SEC Staff Warns That Advisers May Be Required to Register as Broker-Dealers"

On April 5, 2013, David W. Blass, Chief Counsel of the Securities and Exchange Commission’s Division of Trading and Markets, addressed the American Bar Association’s Trading and Markets Subcommittee.1 Mr. Blass’ remarks...more

4/23/2013 - Broker-Dealer Fund Managers Investment Adviser Ranieri Partners Registration SEC

"SEC Recent Developments"

Below is a summary of certain recent guidance from the Securities and Exchange Commission (the “SEC”) that is applicable to investment advisers and broker-dealers, namely: (i) an SEC Risk Alert regarding the Custody Rule...more

4/3/2013 - Broker-Dealer Custody Rule Dodd-Frank Investment Adviser NEP SEC

"The SEC’s Private Equity Enforcement Concerns"

On January 23, 2013, Bruce Karpati, Chief of the Asset Management Unit (the “AMU”) of the Enforcement Division of the Securities and Exchange Commission, addressed the Private Equity International Conference in New York. Mr....more

2/7/2013 - Asset Management Bruce Karpati CCO CFOs Conflicts of Interest COOs Enforcement Misallocation of Funds Private Equity SEC Segregated Portfolio Companies Transparency

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