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Investment Advisers Regulatory Checklist

This coming year will have a revamped ADV with some new requirements. A significant new consideration is the challenges that new cryptocurrencies and other digital assets present for investment advisers and their compliance...more

Investment Adviser Compliance with SEC’s Amended Form ADV

Beginning October 1, 2017, investment advisers filing Form ADV with the Securities and Exchange Commission (the “SEC”) must file using the amended form adopted by the SEC on August 25, 2016 (the “Amended Form ADV”). According...more

Bitcoin and Blockchain: Certain U.S. Regulatory Considerations for Investment Managers

Bitcoin is the first blockchain or distributed ledger technology (“DLT”) to successfully solve a problem succinctly described by Marc Andreessen: “Bitcoin gives us, for the first time, a way for one Internet user to transfer...more

With the Tip of a Hat, a Fund Manager Can Be an ERISA Fiduciary

It’s official. The Department of Labor’s final conflict of interest regulation became applicable on June 9, 2017. Despite the consternation leading up to the issuance of this rule and the expectations of many that the rule...more

Whistleblower Rule Compliance: SEC’s OCIE Issues Risk Alert in Wake of Illustrative Enforcement Actions

On October 24, staff of the Securities Exchange Commission (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert titled “Examining Whistleblower Rule Compliance” (the “Risk Alert”). The Risk...more

Co-Investments in Private Equity: The SEC’s Focus on Disclosure

The trend of utilizing co-investments in private equity continues to grow. A Special Report by Preqin found that 69% of the 320 sponsors surveyed offered co-investment rights to their limited partners, with another 18%...more

Recent Amendment of SEC’S “Qualified Client” Definition

The SEC recently adopted an amendment increasing the net worth threshold set forth in the definition of "qualified client" under the Advisers Act. For an investment adviser that is registered with the SEC, or one that is...more

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