The CrowdStrike computer failures that swept the globe on Friday, July 18, 2024, and persisted through the weekend may have impacted fund advisers relying on the Windows system, possibly triggering an “operations event” that...more
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
Investment Advisers-
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission ("SEC") or The Commonwealth of Massachusetts are required to review their compliance...more
Investment Advisers -
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their compliance...more
2/3/2017
/ Bad Actors ,
CFTC ,
Commodity Pool ,
Confidentiality Policies ,
Cybersecurity ,
Data Privacy ,
Exempt Reporting Advisers (ERAs) ,
FATCA ,
FBAR ,
Financial Statements ,
Form 13F ,
Form ADV ,
Form PF ,
Form PQR ,
Investment Adviser ,
Pay-To-Play ,
Privacy Policy ,
Rule 506 ,
Securities and Exchange Commission (SEC)
As noted in a previous alert, the Securities and Exchange Commission has now issued an Order, effective as of August 15, 2016 (the "Effective Date"), which amends SEC Rule 205-3 (the “Performance Fee Rule”) under the...more
On May 24, 2016, the Securities and Exchange Commission published in the Federal Register a notice of the Commission’s intent to issue an order (the “Proposed Order”) amending SEC Rule 205-3 (the “Performance Fee Rule”) under...more
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more
9/11/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CIP ,
Comment Period ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Internal Controls ,
Investment Adviser ,
Policies and Procedures ,
Proposed Regulation ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Training
Under Rule 204A-1 of the Investment Advisers Act of 1940, a registered investment adviser’s written code of ethics must include requirements for reporting of personal securities holdings and trading activity by the adviser’s...more
Investment Advisers -
Annual Compliance Reviews:
All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least...more
Investment Advisers -
Annual Compliance Reviews:
All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by this Friday, December 13 in order to cover such fees. This deadline applies to the...more
Investment advisers with clients (including funds or separate accounts) that use swaps are reminded to have such clients sign up to the ISDA March 2013 DF Protocol (the “March DF Protocol”) by July 1, 2013....more
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
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
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least annually (and best practice is...more