News & Analysis as of

Investment Adviser Threshold Requirements

Lowenstein Sandler LLP

CFTC Finalizes Long-Awaited Update to Rule 4.7

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On September 12, the Commodity Futures Trading Commission (CFTC or Commission) published a final rule, adopting amendments to CFTC Rule 4.7, which provides exemptive relief from certain compliance obligations to registered...more

Proskauer Rose LLP

Proskauer's Hedge Start: When Is SEC Registration Necessary?

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An initial question faced by any manager launching a hedge fund is whether or not registration as an investment adviser with the U.S. Secutiries and Exchange Commission (SEC) under the Investment Advisers Act of 1940, as...more

Seward & Kissel LLP

SEC Proposes Amendments to the Internet Adviser Exemption

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Who may be interested: Investment Advisers - Quick Take: The SEC recently proposed amendments to modernize the internet adviser exemption in Rule 203A-2(e) under the Advisers Act, which allows specific investment advisers...more

Dechert LLP

SEC Adopts Money Market Fund Reforms; Form PF Amendments

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Today, the Securities and Exchange Commission, by a vote of 3 to 2, approved amendments to Rule 2a-7 and other rules that govern money market funds under the Investment Company Act of 1940 (Amendments). Among other things,...more

Lowenstein Sandler LLP

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

Summaries of recent legislative and regulatory developments with respect to: •SEC’s 2022 Examination Priorities • Proposed Amendments to Form PF Requirements- •Proposed New Rules Applicable to Private Fund Advisers and...more

Goodwin

CFPB Issues Reminder of New Threshold for Reporting HMDA Open-End Lines of Credit Data

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In This Issue. The Consumer Financial Protection Bureau (CFPB) reminded institutions of a new threshold for reporting Home Mortgage Disclosure Act data about open-end lines of credit; the Financial Crimes Enforcement Network...more

White & Case LLP

Mexico’s CNBV updates remote contracting requirements

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On Thursday, September 9, the resolutions that reform, add and repeal the general rules on the prevention and identification of operations with resources of illicit origin applicable to financial cooperative associations...more

White & Case LLP

Regulatory update to remote onboarding procedures of various financial institutions

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On Thursday, September 9, the resolutions that reform, add and repeal the general rules on the prevention and identification of operations with resources of illicit origin applicable to financial cooperative associations...more

Winstead PC

SEC Increases Financial Thresholds for Qualified Clients

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On August 16, 2021, the financial thresholds specified in the definition of “qualified client” under Rule 205‑3 of the Investment Advisers Act of 1940 (“Advisers Act”) will increase (i) from $1 million to $1.1 million (assets...more

Stinson LLP

SEC Increases Qualified Client Threshold

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In an order effective August 16, 2021, the Securities and Exchange Commission (SEC) increased the dollar amount tests in the "qualified client" definition under Advisers Act Rule 205-3....more

Lowenstein Sandler LLP

SEC Raises The Dollar Threshold For Qualified Clients

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What You Need To Know: Effective August 16, 2021, the Assets-Under-Management Test will increase to $1.1 million, and the Net Worth Test will increase to $2.2 million. On June 17, 2021, the U.S. Securities and...more

Kramer Levin Naftalis & Frankel LLP

SEC Increases Slightly ‘Qualified Client’ Dollar Amount Thresholds

On June 17, 2021, the Securities and Exchange Commission (SEC) issued an order (the “Order”) approving a revision to Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which exempts...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - February 2021

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The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

Latham & Watkins LLP

SEC Proposal: Will You Still Be a 13F Filer?

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The SEC proposes a welcome and significant increase in the 13F reporting threshold from US$100 million to US$3.5 billion. On July 10, 2020, the US Securities and Exchange Commission (SEC) released a proposed rule amendment...more

Proskauer Rose LLP

SEC Proposes Increasing the 13F Threshold to $3.5 billion

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On July 10, 2020, the Securities and Exchange Commission (“SEC”) proposed significantly increasing the reporting threshold requiring the filing of a Form 13F to $3.5 billion, a 35-fold increase from the current threshold....more

Mayer Brown Free Writings + Perspectives

Rule 701 Amendment and Concept Release

At yesterday’s open meeting, the Securities and Exchange Commission adopted an amendment to Rule 701. The Commission was mandated to adopt an amendment to Rule 701 by the Economic Growth, Regulatory Relief and Consumer...more

Robinson & Cole LLP

SEC Registered Investment Advisers—A Review of 2016 and a Look at What’s Ahead for 2017

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As we near the seventh anniversary of the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), private equity and hedge fund advisers are subject to an ever-increasing degree of supervision...more

Dechert LLP

2016/07/12 SEC Adopts Inflation-Based Adjustment to “Qualified Client” Thresholds

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The U.S. Securities and Exchange Commission issued a final order (Order) on June 14, 2016, to adjust for inflation the “qualified client” thresholds applicable when a registered investment adviser charges a performance fee in...more

Morrison & Foerster LLP - JOBS Act

SEC Increases Net Worth Threshold for “Qualified Clients” under Rule 205-3 of the Advisers Act

On June 14, 2016, the SEC issued an order (the “Order”) to increase the net worth threshold for “qualified clients” under Rule 205-3 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), from $2 million to...more

Goodwin

Financial Services Weekly News - June 2016 #4

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Regulatory Developments - SEC Issues Order Approving Inflation Adjustments to “Qualified Client” Dollar Thresholds for Investment Adviser Performance Fee Rule - On June 14, the SEC issued an order approving...more

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