Tiffany Ford

Foley Hoag LLP

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Latest Publications


Late Fee for NFA Forms PQR and PR Filings Effective Starting September 30, 2016

The National Futures Association recently amended NFA Compliance Rule 2-46 in order to impose late fees for its commodity pool operator (CPO) and commodity trading adviser (CTA) members that do not make quarterly filings on...more

6/30/2016 - Commodity Pool CTA Filing Deadlines Late Fees National Futures Association NFA

CFTC 4.13(a)(3) Annual Affirmations Due February 29

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

2/15/2016 - CFTC Deadlines Exemptions Fund Managers National Futures Association Registration Requirement

NFA Amends Interpretive Notice Regarding NFA Compliance Rules 2-7 and 2-24 and Registration Rule 401

Proficiency Requirements for Security Futures Products - The term security futures product (“SFP”) encompasses security futures and options on security futures. The term security future includes both futures on a single...more

12/22/2015 - Audits CFTC Commodity Futures Modernization Act of 2000 (CFMA) FINRA Futures National Futures Association Training Requirements

CFTC and NFA Issue FAQS on Form CPO-PQR and Form CTA-PR

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (the “CFTC”) recently issued answers to Frequently Asked Questions (“FAQs”) regarding CFTC Form CPO-PQR applicable to...more

12/17/2015 - CFTC Commodity Pool CTA National Futures Association Swap Dealers

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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