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The Corporate Transparency Act: Impact on Private Fund Managers

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

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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

Reminder: Renewal and Notice Filing Fees for Investment Advisers due by December 11, 2023

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

Reminder: Increased “Qualified Client” Dollar Amount Tests to Take Effect August 16, 2021

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

Reminder: FINRA Entitlement Certification Due by July 19, 2021

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

SEC Adopts New Marketing Rule for Investment Advisers

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

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 14, 2020

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 Adviser Agrees to Pay $5 Million for Compliance Deficiencies in Valuing Client Assets

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

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 17

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

OCIE Issues Risk Alert on Compliance Deficiencies Relating to the Cash Solicitation Rule

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

Impacts of New CFIUS Pilot Program on Investment Funds

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

SEC Brings First Enforcement Action for Identity Theft Red Flags Rule Violations

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

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