Tiffany Ford

Foley Hoag LLP

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Latest Publications


Cayman Islands Directors Registration and Licensing Law: CIMA Requires Registration or Licensing of Fund Directors by September 3...

Under the Cayman Islands Directors Registration and Licensing Law 2014 (the “Law”), beginning June 4, 2014 directors of (a) “mutual funds” regulated under the Cayman Islands Mutual Funds Law (2013 Revision) and (b) companies...more

7/23/2014 - Board of Directors CIMA Directors Licensing Rules Registration

CFTC 4.13(a)(3) Annual Affirmations Due March 3, 2014

As a reminder, fund managers relying on the exemption from registration with the US Commodity Futures Trading Commission (the “CFTC”) set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more

2/11/2014 - CFTC De Minimus Quantity Exemption Filing Deadlines

SEC Issues Risk Alert on Investment Advisers’ Due Diligence Processes for Selecting Alternative Investments

On January 28, 2014, 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...more

2/11/2014 - Due Diligence Investment Advisers Act of 1940 SEC

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 13

As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by this Friday, December 13 in order to cover such fees. This deadline applies to the...more

12/11/2013 - Deadlines Filing Fees Investment Adviser Notice Requirements Renewal Fees

New Form PR Quarterly Filing Requirement Now in Effect for CTAs

On September 16, 2013, the National Futures Association (NFA) issued a notice on the new quarterly filing requirements for commodity trading advisers (CTAs). Previously, under Commodity Futures Trading Commission (CFTC)...more

9/30/2013 - CFTC CTA Filing Requirements NFA

Reminder: Private Fund Due Diligence Required to Comply with “Bad Actor” Provisions Under Rule 506 Which Take Effect Monday,...

As a reminder, under amendments to Rule 506 adopted by the Securities and Exchange Commission on July 10, 2013, any private fund conducting an ongoing offering of its securities is required to undertake due diligence to...more

9/20/2013 - Bad Actors Due Diligence Private Funds Rule 506 Offerings SEC

Reminder: Form ADV Annual Amendment Due April 1

As a reminder, all SEC-registered advisers, state-registered advisers, SEC-exempt reporting advisers and state-exempt reporting advisers with a fiscal year ending December 31, 2012 must update and file their Form ADV by April...more

3/22/2013 - Form ADV SEC

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