Robert Sawyer

Robert Sawyer

Foley Hoag LLP

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Leap Year Means Earlier Due Date for Form ADV

As a reminder, Form ADV for registered advisers (Parts 1 and 2A) and Exempt Reporting Advisers (relevant portions of Part 1) must be updated within 90 days after the end of their fiscal year. For advisers with a fiscal year...more

3/17/2016 - Annual Filings Filing Deadlines Form ADV Registered Investment Advisors

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...more

1/23/2016 - AIFMD CFTC Commodities Confidentiality Agreements CPOs EU FATCA Financial Statements FINRA Form ADV Form PF Hedge Funds NFA Pay-To-Play Popular Privacy Policy Registered Investment Advisors SEC Swaps

SEC Issues Report on Review of “Accredited Investor” Definition

On December 18, 2015, the Securities and Exchange Commission (the “SEC”) issued a report evaluating the definition of “accredited investor” as part of its obligations under the Dodd-Frank Wall Street Reform and Consumer...more

1/11/2016 - Accredited Investors Capital Raising Comment Period Dodd-Frank Regulation D SEC

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

12/11/2015 - Filing Fees Investment Adviser Registered Investment Advisors Renewal Fees SEC

Possible Examination by SEC of Exempt Reporting Advisers

Marc Wyatt, Acting Director of the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”), recently took part in a meeting of the ABA Hedge Fund Sub-Committee on November 20,...more

12/4/2015 - Compliance Form ADV OCIE Risk-Based Approaches SEC SEC Examination Priorities

SBIC Advisers Relief Act Expected to be Adopted into Law

On December 4, 2015, President Obama is expected to sign into law The SBIC Advisers Relief Act, which amends several key registration provisions and exemptions of the Investment Advisers Act of 1940 (the “Advisers Act”), that...more

12/4/2015 - Amended Legislation Exemptions Investment Advisers Act of 1940 Preemption SBIC

OCIE Issues Risk Alert Relating to Outsourced Chief Compliance Officers

On November 9, 2015, the Office of Compliance Inspections and Examinations (“OCIE”) released the findings of its Outsourced CCO Initiative, which examined nearly 20 investment advisers and investment companies that are...more

11/13/2015 - Chief Compliance Officers Compliance OCIE Outsourcing Risk Alert SEC

SEC to Recommend Additional Compliance Rules for Investment Advisers

David W. Grim, Director of the SEC’s Division of Investment Management (the “Division”), recently noted in testimony before a U.S. House of Representatives subcommittee that the Division is developing new rule recommendations...more

11/10/2015 - Compliance Derivatives Dodd-Frank Registered Investment Advisors SEC Third-Party

FinCEN Proposed AML Rule For Investment Advisers

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more

9/11/2015 - Anti-Money Laundering Bank Secrecy Act CIP Comment Period Currency Transaction Reports (CTR) Financial Institutions FinCEN Internal Controls Investment Adviser Policies and Procedures Proposed Regulation Recordkeeping Requirements Reporting Requirements SEC Suspicious Activity Reports Training

SEC Division of Investment Management Issues Guidance on Personal Trade Reporting of Accounts Over Which Reporting Persons Have No...

Under Rule 204A-1 of the Investment Advisers Act of 1940, a registered investment adviser’s written code of ethics must include requirements for reporting of personal securities holdings and trading activity by the adviser’s...more

7/1/2015 - Corporate Officers Ethics Investment Adviser Investment Advisers Act of 1940 Non-Public Information SEC

SEC Proposes Rules Imposing Additional Reporting and Recordkeeping Requirements for Investment Advisers

On May 20, 2015, the SEC announced proposals to modify and increase the amount of information that it collects from investment companies (“ICs”) and investment advisers (“IAs”) and to create new rules that impose additional...more

5/26/2015 - Comment Period Disclosure Requirements Investment Adviser Investment Funds Proposed Regulation Recordkeeping Requirements SEC

SEC Issues Cybersecurity Guidance Update for Investment Advisers

On April 28, 2015, the SEC’s Division of Investment Management (the “Division”) issued a Guidance Update regarding the SEC’s initiative to assess cybersecurity preparedness and threats in the securities industry, further...more

4/30/2015 - Compliance Cybersecurity Data Protection Investment Adviser SEC

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

1/19/2015 - CPOs Filing Requirements Financial Statements Form ADV Form PF Investment Adviser SEC

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

11/13/2014 - Filing Deadlines Filing Fees Investment Adviser

CFTC Issues Exemptive Relief to Harmonize with JOBS Act Amendments to Regulation D and Rule 144A

The U.S. Commodity Futures Trading Commission (“CFTC”) issued an Exemptive Letter on September 8, 2014 (“Exemptive Letter”) providing that an issuer relying on Rule 506(c) of Regulation D and resellers relying on Rule 144A,...more

9/12/2014 - CFTC CPO Exemptive Orders General Solicitation JOBS Act Regulation D Rule 144A Rule 506(c)

Republican State Parties Challenge SEC’s Pay-to-Play Rule

On August 7, 2014, the New York Republican State Committee and Tennessee Republican Party (the “Plaintiffs”) filed a civil suit against the Securities and Exchange Commission (the “SEC”) seeking to overturn Rule 206(4)-5...more

8/18/2014 - Investment Advisers Act of 1940 Pay-To-Play SEC

SEC Issues No-Action Letter on the Definition of Knowledgeable Employee

On February 7, 2014 the staff of the Division of Investment Management of the Securities and Exchange Commission (the “SEC”) issued a no-action letter to the Managed Funds Association (the “No-Action Letter”), providing...more

3/21/2014 - Actual or Constructive Knowledge Investment Company Act of 1940 No-Action Letters SEC

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

1/28/2014 - Commodities CPO Deadlines Financial Adviser Form 13F Investment Adviser SEC

SEC Clarifies Application of Qualified Client Test for Related Advisers

Under SEC Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”), an SEC registered investment adviser is permitted to enter into an engagement that includes an incentive compensation component, provided...more

11/12/2013 - Investment Adviser Investment Advisers Act of 1940 Qualified Client SEC

SEC: Zero Tolerance for Short Selling Violations

On September 17, 2013, the Securities and Exchange Commission (the “SEC”) announced enforcement actions against 23 firms for violations of Rule 105 of Regulation M. Rule 105 prohibits the purchase of securities in a follow-on...more

10/21/2013 - Enforcement Actions Policy Violations Regulation M SEC Short Sales Zero Tolerance Policies

SEC Issues National Exam Program Risk Alert Regarding Investment Advisers’ Business Continuity Plans

On August 27, 2013, the Office of Compliance Inspections and Examinations of the Securities and Exchange Commission (the “SEC”) issued a National Exam Program Risk Alert (the “Risk Alert”) resulting from its review of the...more

9/20/2013 - Business Continuity Plans Disaster Preparedness Hurricane Sandy Investment Adviser Investment Advisers Act of 1940 Natural Disasters Risk Management SEC

SEC Comments Regarding Current Hedge Fund Priorities

On September 12, 2013, the SEC published a recent speech by Norm Champ, Director of the SEC’s Division of Investment Management, in which he notes his views as to current priorities for the SEC in its regulation of hedge fund...more

9/18/2013 - Compliance Enforcement Hedge Funds SEC

SEC Offers Custody Rule Relief to Venture Capital and Private Equity Funds

Following the adoption of the Dodd-Frank Act and amendments to the rules under the Investment Advisers Act of 1940 (the “Advisers Act”) adopted by the SEC, many previously unregistered managers to private funds, including...more

8/5/2013 - Custody Rule Dodd-Frank Investment Adviser Investment Advisers Act of 1940 Private Equity Funds SEC Venture Capital

SEC Passes Final Rules Implementing JOBS Act Amendments to Regulation D

On July 10, 2013, the SEC voted 4-1 to approve final rules, which included the adoption of new subsection (c) to SEC Rule 506 of Regulation D under the Securities Act of 1933, permitting the use of general solicitation and...more

7/12/2013 - Accredited Investors Advertising CFTC General Solicitation JOBS Act Regulation D SEC

Reminder: Deadline for Obtaining CFTC Interim Compliance Identifier for Parties Trading in Swaps

On March 15, 2013, the Commodity Futures Trading Commission’s Division of Market Oversight and Office of Data and Technology issued an advisory, reminding all swap market participants of the imminent deadline to comply with...more

3/22/2013 - CFTC CICIs Disclosure Requirements Recordkeeping Requirements Swaps

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