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Reminder: New Say-on-Pay Disclosures for Institutional Investment Managers Now Effective

The Securities and Exchange Commission (“SEC”) adopted amendments to Form N-PX on November 2, 2022. Previously, Form N-PX applied solely to registered investment companies (i.e., mutual funds, exchange-traded funds and...more

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 at the state level are required to review their compliance policies and...more

Final Private Fund Adviser Rules

On August 23, 2023, the Securities and Exchange Commission (the “SEC”) approved by a 3-2 vote a final rule enacting a series of wide-sweeping changes to the regulation of the private funds industry (the “Final Rule”). While...more

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 at the state level are required to review their compliance policies and...more

Reminder: Increased “Qualified Client” Dollar Amount Tests to Take Effect August 16, 2021

Effective August 16, 2021, the increased dollar amount thresholds for “qualified clients” as defined under Rule 205-3 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) will go into effect. ...more

Reminder: FINRA Entitlement Certification Due by July 19, 2021

The 2021 FINRA Entitlement Certification period for broker-dealers, funding portals, investment advisers and US-based regulators that participate in the FINRA Entitlement program commenced on April 19, 2021 and ends on July...more

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 16, 2019

As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 16, 2019 in order to cover such fees (with a recommendation from...more

CFTC 4.13(a)(3) Annual Affirmations Due March 1, 2019

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

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 U.S. Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more

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 compliance...more

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 compliance...more

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 18

As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by December 18 in order to cover such fees. This deadline applies to the following...more

AIFMD: ESMA Recommends the First Wave of Non-EU Countries to Obtain a Europe-Wide Marketing Passport

On July 30, 2015, the European Securities and Markets Authority (ESMA) released its advice to the European Parliament, Council of the European Union and the European Commission on the application of the passport to non-EU...more

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

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 12

As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by December 12 in order to cover such fees. This deadline applies to the following...more

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

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

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

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

SEC Releases 2013 Examination Priorities

On February 21, 2013, the US Securities and Exchange Commission (the “SEC”) released its examination priorities for 2013. The priorities were published by National Examination Program (“NEP”), a program administered through...more

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

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