On April 17, 2013, U.S. Rep. Keith Ellison (D-Minn.) reintroduced the Inclusive Prosperity Act of 2013 (H.R. 1579) (the "Bill"), a financial transaction tax that, according to its supporters, would provide the federal...more
Norm Champ, Director, SEC Division of Investment Management, recently noted that SEC rules prohibit certain advertisements by registered advisers. Mr. Champ noted the SEC has heard from advisers to private funds,...more
The SEC has issued a Risk Alert on compliance with its custody rule for investment. It notes that with respect to advisers to audited pooled investment vehicles, its examinations found some failed to meet requirements to...more
The Office of Compliance Inspections and Examinations, or OCIE, administers the SEC’s nationwide examination and inspection program. The National Examination Program, or NEP, has published its examination priorities to...more
On 11 February 2013, the European Securities and Markets Authority (ESMA) published its final Guidelines on remuneration of alternative investment fund managers (AIFMs) under the Alternative Investment Fund Managers Directive...more
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 annually (and best practice is...more
Bruce Karpati, Chief, SEC Enforcement Division’s Asset Management Unit, recently described enforcement priorities with respect to hedge funds. He noted the Asset Management Unit, comprised of 75 staff across 11 offices,...more
The Internal Revenue Service this week released Announcement 2012-42 (the Announcement), which postpones until 2014 the need for foreign hedge funds and private equity funds to request Foreign Account Tax Compliance Act...more
Dear Clients and Friends: In October, federal agencies proposed two new sets of regulations under the Dodd-Frank Act. The proposals — to implement the Volcker Rule and to create standards to designate certain nonbanks...more
Update on the new rules governing private funds under Dodd-Frank....more
On June 22, 2011, the Securities and Exchange Commission ("SEC") adopted final rules under the Private Fund Investment Advisers Registration Act of 2010 (the “Act”), contained in the Dodd-Frank Wall Street Reform and Consumer...more
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