On March 12, 2025, the staff of the U.S. Securities and Exchange Commission (“SEC”) issued a no-action letter clarifying that issuers relying on Rule 506(c) of Regulation D, the private offering safe harbor permitting general...more
On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted Rule 13f-2 and related Form SHO pursuant to the Securities Exchange Act of 1934. Rule 13f-2 requires that any party meeting the definition of...more
INVESTMENT ADVISERS -
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 9, 2024 in order to cover such fees (with a recommendation from IARD...more
12/6/2024
/ Deadlines ,
Filing Deadlines ,
Filing Fees ,
Fund Transfers ,
IARD ,
Investment Adviser ,
Registered Investment Advisors ,
Registration Requirement ,
Renewal Options ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
The Commodity Futures Trading Commission (CFTC) recently adopted a final rule amending CFTC Rule 4.7. CFTC Rule 4.7 provides an exemption from certain disclosure, recordkeeping and reporting requirements for registered...more
Private fund managers are reminded that the Corporate Transparency Act (CTA) may trigger reporting obligations to the Department of the Treasury’s Financial Crimes Enforcement Network for private fund managers and the private...more
INVESTMENT ADVISERS -
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more
2/2/2024
/ Commodity Pool ,
Commodity Trading Advisors (CTAs) ,
Exemptions ,
Filing Deadlines ,
Filing Requirements ,
Investment Adviser ,
Investment Companies ,
Investment Management ,
Reporting Requirements ,
Required Forms ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 11, 2023 in order to cover such fees (with a recommendation from...more
INVESTMENT ADVISERS -
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and...more
2/14/2022
/ Annual Filings ,
Broker-Dealer ,
California Consumer Privacy Act (CCPA) ,
Cayman Islands ,
Commodity Pool ,
Commodity Trading Advisors (CTAs) ,
CPOs ,
Cybersecurity ,
Data Protection Acts ,
Deadlines ,
Eligibility ,
Exempt Reporting Advisers (ERAs) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Statements ,
Form 13F ,
Form 13H ,
Form ADV ,
Form PF ,
Form PQR ,
General Data Protection Regulation (GDPR) ,
IARD ,
Investment Adviser ,
Multi-Factor Authentication ,
Privacy Policy ,
Rule 506 ,
Securities and Exchange Commission (SEC) ,
Security Audits
Effective August 16, 2021, the increased dollar amount thresholds for “qualified clients” as defined under Rule 205-3 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) will go into effect. ...more
The 2021 FINRA Entitlement Certification period for broker-dealers, funding portals, investment advisers and US-based regulators that participate in the FINRA Entitlement program commenced on April 19, 2021 and ends on July...more
On December 22, 2020, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments under the Investment Advisers Act of 1940 modernizing the rules governing investment adviser marketing. The amendments replace and...more
3/10/2021
/ Advertising ,
Amended Rules ,
Books & Records ,
Cash Solicitation Rule ,
Compliance ,
Form ADV ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Marketing ,
No-Action Letters ,
Securities and Exchange Commission (SEC)
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 14, 2020 in order to cover such fees (with a recommendation from...more
Investment Advisers -
ANNUAL COMPLIANCE REVIEWS -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and procedures...more
2/7/2020
/ Alternative Investment Fund Managers Directive (AIFMD) ,
California Consumer Privacy Act (CCPA) ,
Cayman Islands ,
Cooperative Compliance Regime ,
Cybersecurity ,
Data Protection ,
Derivatives ,
Employee Privacy Rights ,
EU ,
Exemptive Rule ,
FATCA ,
FBAR ,
Form ADV ,
Form CRS ,
Form D Filing ,
Form PQR ,
General Data Protection Regulation (GDPR) ,
Investment ,
Investment Adviser ,
Pay-To-Play ,
Personal Data ,
Popular ,
Securities and Exchange Commission (SEC) ,
Swaps
On June 4, 2019, the Securities and Exchange Commission (“SEC”) announced that Deer Park Road Management Company, LP (“Deer Park”), a prominent private fund manager in the mortgage-backed securities space and registered...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 17 in order to cover such fees (with a recommendation from IARD to...more
On October 31, 2018, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a Risk Alert summarizing the most common deficiencies relating to Rule 206(4)-3 (the “Cash...more
On October 10, 2018, the Department of the Treasury, which oversees the Committee on Foreign Investment in the United States (“CFIUS”), released interim regulations to implement portions of the Foreign Investment Risk Review...more
On September 26, in the Securities and Exchange Commission’s (“SEC”) first enforcement action for violations of Regulation S-ID (the “Identity Theft Red Flags Rule”), Voya Financial Advisors Inc. (“VFA”), an SEC-registered...more