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2014-15 Compliance Developments & Calendar for Private Fund Advisers

Introduction - Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more

10/6/2014 - Affiliates AIFMD Broken Windows Chief Compliance Officers CPO Cybersecurity Export Controls FATCA Foreign Affiliates Foreign Investment General Solicitation Investment Adviser Policies and Procedures Private Funds Proxy Voting Guidelines Reporting Requirements SEC Social Media Policy

CFTC Publishes Long-Awaited JOBS Act Relief

The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more

9/12/2014 - CFTC CPO Disclosure Requirements Exemptions General Solicitation JOBS Act No-Action Letters Private Offerings Reporting Requirements Rule Rule 144A Rule 506(c) SEC

SEC Staff Provides Clarification of Scope of Bad Actor Disqualification

The staff of the Securities and Exchange Commission’s Division of Corporation Finance published “Compliance and Disclosure Interpretations” (CDIs) on Wednesday, December 4, 2013, that provide important clarification regarding...more

12/6/2013 - Accredited Investors Bad Actors Compliance Disclosure Requirements General Solicitation JOBS Act Rule 506 Offerings SEC

SEC Permits General Solicitation but Proposes Significant Impediments to its Use

On July 10, 2013, the Securities and Exchange Commission (SEC) adopted amendments to its safe harbor rule for private placements of securities, Rule 506 of Regulation D under the Securities Act of 1933 (the “Securities Act”)....more

7/26/2013 - Accredited Investors Advertising Bad Actors General Solicitation Marketing Regulation D Rule 144A Rule 506 Offerings Safe Harbors SEC Securities Act of 1933 Verification Requirements

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