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
Under the Cayman Islands Directors Registration and Licensing Law 2014 (the “Law”), beginning June 4, 2014 directors of (a) “mutual funds” regulated under the Cayman Islands Mutual Funds Law (2013 Revision) and (b) companies...more
On February 7, 2014 the staff of the Division of Investment Management of the Securities and Exchange Commission (the “SEC”) issued a no-action letter to the Managed Funds Association (the “No-Action Letter”), providing...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
On July 10, 2013, the SEC voted 4-1 to approve final rules, which included the adoption of new subsection (c) to SEC Rule 506 of Regulation D under the Securities Act of 1933, permitting the use of general solicitation and...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
The HM Treasury has issued a Q&A in which it suggests upcoming changes to the timetable for implementing the Alternative Investment Fund Managers Directive (the “AIFMD”) in the United Kingdom. The HM Treasury is the UK...more
As a reminder, smaller private fund advisers registered with the SEC and “large private equity fund advisers” with a fiscal year-end of December 31 must file their Form PF with the SEC by April 30, 2013....more
The first compliance date under the European Union’s recently adopted Alternative Investment Fund Managers Directive (the “AIFMD”) is July 22, 2013....more
Managers Who Use Swaps Should Act Now -
Managers of funds and separately managed accounts that use swaps are reminded that they (or their clients) must complete the DF Protocol Adherence Letter and DF Protocol...more
On March 15, 2013, the Commodity Futures Trading Commission’s Division of Market Oversight and Office of Data and Technology issued an advisory, reminding all swap market participants of the imminent deadline to comply with...more
As a reminder, all SEC-registered advisers, state-registered advisers, SEC-exempt reporting advisers and state-exempt reporting advisers with a fiscal year ending December 31, 2012 must update and file their Form ADV by April...more
As a follow up to our earlier Foley Adviser, the compliance deadlines have been extended for mandatory clearing of European iTraxx credit default swap (CDS) indices. ...more
Investment managers who use swaps on behalf of their clients (including funds) are reminded that the phase-in for mandatory clearing of certain types of swaps has begun. Investment managers should be analyzing (a) the types...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
Investment managers who invest in futures or swaps are reminded that important registration and/or filing deadlines with the U.S. Commodity Futures Trading Commission (the “CFTC”) are quickly approaching....more