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DOL Reinstates Five-Part-Test for Investment Advice Fiduciaries and Proposes New Exemption

After several years of uncertainty as to the appropriate standard for determining when an investment adviser will be deemed to be a fiduciary under ERISA, the U.S. Department of Labor (the “DOL”) has finally issued clear...more

CFTC 4.13(a)(3) Annual Affirmations Due February 29

As a reminder, fund managers relying on the exemption from registration with the US Commodity Futures Trading Commission (the “CFTC”) set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more

CFTC 4.13(a)(3) Annual Affirmations Due March 2

As a reminder, fund managers relying on the exemption from registration with the US Commodity Futures Trading Commission (the “CFTC”) set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more

2/5/2015  /  CFTC , Deadlines , Exemptions , Registration

CFTC 4.13(a)(3) Annual Affirmations Due by March 1st

As a reminder, fund managers relying on the exemption from registration with the U.S. Commodity Futures Trading Commission (the "CFTC") set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more

Massachusetts Securities Division Sending Letters Requiring Documentation from MA Exempt Reporting Advisers

The Massachusetts Securities Division ("the Division") is currently sending letters to exempt reporting advisers in Massachusetts ("MA ERAs") who manage private funds which rely on the exclusion from the definition of...more

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