Michael L. Sherman

Michael L. Sherman

Dechert LLP

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SEC Proposes to Amend Form ADV and Investment Adviser Recordkeeping Rules

The U.S. Securities and Exchange Commission (SEC or Commission) recently proposed amendments to Form ADV and to Rule 204-2 (Recordkeeping Rule) and other rules under the Investment Advisers Act of 1940, as amended (Advisers...more

7/17/2015 - CCO Disclosure Requirements Dodd-Frank Form ADV Investment Adviser Investment Advisers Act of 1940 RAUM Recordkeeping Requirements Risk Assessment SEC Social Media Umbrella Registration

Credit Risk Retention Final Rule: Enforcement and Compliance Considerations

Predicting enforcement of the final rule regarding U.S. risk retention is an uncertain task. This OnPoint is designed to provide guidance on possibilities related to consequences of non-compliance, enforcement approaches by...more

12/16/2014 - Asset-Backed Securities CMBS Collateralized Loan Obligations Dodd-Frank Enforcement Guidance Final Rules Private Right of Action Prudential Regulation Authority Risk Retention

U.S. Risk Retention Final Rule: Playing it Forward for CLOs

We will leave the hand wringing and teeth gnashing to others. We expect there will be a lot of that in the days ahead. We have had our say on the misguided premises and tortured statutory interpretation underpinning the final...more

10/23/2014 - Collateralized Debt Obligations Collateralized Loan Obligations Dodd-Frank FDIC Risk Retention Securities Exchange Act Volcker Rule

Financial Services Quarterly Report - Third Quarter 2013: U.S. Private Offerings: SEC Approves JOBS Act Requirement to Permit...

The SEC has amended1 Rule 506 of Regulation D and Rule 144A under the Securities Act of 1933 (“Securities Act”) to (1) permit, in certain circumstances, an issuer to engage in general solicitation and general advertising in...more

10/7/2013 - Accredited Investors Bad Actors Dodd-Frank General Solicitation JOBS Act Regulation D Rule 144A Rule 506 Offerings SEC

SEC Approves Final Rules that (1) Permit General Solicitation and General Advertising in Rule 506 and Rule 144A Offerings and (2)...

The SEC has amended Rule 506 of Regulation D and Rule 144A under the Securities Act of 1933 (Securities Act) to (1) permit, in certain circumstances, an issuer to engage in general solicitation and general advertising in...more

7/28/2013 - Accredited Investors Advertising Bad Actors Broker-Dealer Dodd-Frank Form D Filing Fund Managers General Solicitation Rule 144A Rule 506 Offerings Safe Harbors SEC Securities Act of 1933 Social Media

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