News & Analysis as of

Registration Investment Advisers Act of 1940

Stinson - Corporate & Securities Law Blog

SEC Updates Form ADV

The SEC has adopted final rules requiring investment advisers to provide additional information on Form ADV and other matters. The final rules: - require information about an investment adviser’s separately managed...more

Troutman Pepper

Cease and Desist Proceedings Against an Asset Manager for Acting as an Unlicensed Broker-Dealer

Troutman Pepper on

Industry participants are well-advised to review their practices to ensure compliance with the Advisers Act, and the SEC’s and SEC’s Staff’s interpretations of when registration as a broker-dealer is required....more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Issues Fine in Pay-to-Play Rule and Registration Requirement Violation Case"

On June 20, 2014, the Securities and Exchange Commission ("SEC") censured and fined investment adviser TL Ventures Inc. for violating the SEC's pay-to-play rule, Rule 206(4)-5 (the "Rule"), and failing to properly register...more

Dorsey & Whitney LLP

SEC’s First Advisers Act Pay-To-Play Action

Dorsey & Whitney LLP on

The Commission brought its first pay-to-play action involving political campaign contributions under the Investment Advisers Act. The proceeding is predicated on the integration of two firms which claimed to be exempt from...more

Broker-Dealer Compliance + Regulation

SEC Staff Elaborates on Venture Capital Adviser Exemption

The SEC’s Division of Investment Management provided advisers to venture capital funds with guidance on fund structures that do not jeopardize an adviser’s ability to rely on the exemption from registration provided by...more

Goodwin

Private Fund Adviser Receives Exemptive Relief from Two-Year Compensation Ban under Pay-to-Play Rule Triggered by Contribution to...

Goodwin on

An SEC-registered adviser (the “Adviser”) was granted exemptive relief pursuant to Rule 206(4)-5 (the “Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) from the Rule’s two-year prohibition on receiving...more

Broker-Dealer Compliance + Regulation

House Passes Bill to Restore Registration Exemption for Private Equity Fund Advisers

The United States House of Representatives passed a bill on December 4, 2013, that would restore an exemption from registration to advisers of certain private equity funds that limit leverage, an attempt to undo another...more

Broker-Dealer Compliance + Regulation

Non-U.S. broker-dealers and investment advisers may have U.S. registration requirements when existing clients relocate to the...

The SEC recently reminded non-U.S. broker-dealers and advisers with clients that relocate to the United States that they may be required to register under the U.S. securities laws. On July 31, 2013, the SEC sanctioned a...more

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