On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted Rule 13f-2 and related Form SHO pursuant to the Securities Exchange Act of 1934. Rule 13f-2 requires that any party meeting the definition of...more
On October 13, 2023, the SEC adopted Rule 13f-2 and related Form SHO pursuant to the Securities Exchange Act of 1934 (the “Exchange Act”). Rule 13f-2 seeks to address Congress’ directive under Section 929X of the Dodd-Frank...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
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...more
1/23/2016
/ Alternative Investment Fund Managers Directive (AIFMD) ,
CFTC ,
Commodities ,
Confidentiality Agreements ,
CPOs ,
EU ,
FATCA ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Statements ,
Form ADV ,
Form PF ,
Hedge Funds ,
NFA ,
Pay-To-Play ,
Popular ,
Privacy Policy ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Swaps
David W. Grim, Director of the SEC’s Division of Investment Management (the “Division”), recently noted in testimony before a U.S. House of Representatives subcommittee that the Division is developing new rule recommendations...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
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
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
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
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