Robert Sawyer

Robert Sawyer

Foley Hoag LLP

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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

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

3/1/2013 - Broker-Dealer Investment Adviser NEP Pay-To-Play Prioritized Examination SEC

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