Michael Caccese

Michael Caccese

K&L Gates LLP

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Notification Requirement for Firms Claiming Compliance with the Global Investment Performance Standards (GIPS)

The GIPS Executive Committee has approved a new requirement, effective January 1, 2015, that any firm claiming compliance with GIPS must annually notify the CFA Institute of such claim by June 30. Each GIPS-compliant firm...more

10/24/2014 - Compliance Investors JOBS Act Regulation D Regulation S Rule 506 Offerings Safe Harbors SEC Securities Act of 1933

Removal of Credit Ratings References

On July 23, 2014, in connection with the adoption of final rules governing the structure and operation of money market funds, the Securities and Exchange Commission (SEC) re-proposed amendments to Rule 2a-7 to implement...more

8/8/2014 - Credit Ratings Dodd-Frank Financial Regulatory Reform Money Market Funds SEC

Summary of New Money Market Fund Rules Adopted by the SEC

On July 23, 2014, the Securities and Exchange Commission (the SEC) adopted final rules governing the structure and operation of money market funds, in a release adopting amendments to Rule 2a-7 under the Investment Company...more

8/7/2014 - Dodd-Frank Final Rules Floating NAV Investment Company Act of 1940 IRS LiquidAlts Money Market Funds Mutual Funds Redemption Gates SEC U.S. Treasury

SEC Adopts Floating NAV and Liquidity Fees/Redemption Gates Rules for Money Funds

On July 23, 2014, the Securities and Exchange Commission (the SEC) adopted final rules governing the structure and operation of money market funds. These rules are discussed in a release adopting amendments to Rule 2a-7 under...more

7/28/2014 - Compliance Investment Company Act of 1940 Liquidity Fees Money Market Funds NAV SEC

SEC Administrative Law Judge Bars Investment Manager for Misrepresenting GIPS Compliance

On May 27, 2014, an administrative law judge (ALJ) found ZPR Investment Management, Inc. (ZPRIM) and its former owner, Max Zavanelli, to have violated the Investment Advisers Act of 1940 for publishing misleading...more

6/18/2014 - Advertising Compliance Enforcement Actions False Advertising Misleading Statements SEC

Update on GIPS Guidance Statement on Pooled Funds and Potential Impacts - Remarks from the GIPS Standards 2013 Annual Conference

At the Global Investment Performance Standards (“GIPS®”, or “GIPS Standards”) 2013 Annual Conference, held Sept. 19th and 20th in Boston, MA, speakers Annie Lo (CFA Institute) and Ann Putallaz (AFP Consulting, LLC) and...more

10/16/2013 - Advertising GIPS Standards Pooled Investment Vehicles

SEC Proposes Major Revisions to Money Market Fund Rules

On June 5, 2013, the Securities and Exchange Commission (“SEC”) voted to release its long-awaited proposals to make significant revisions to the rules governing money market mutual funds (“money funds”), as well as to adopt...more

6/17/2013 - Disclosure Requirements FSOC GAAP Liquidity Fees Money Market Funds Mutual Funds NAV Right of Redemption SEC Stress Tests

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