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SEC Raises The Dollar Threshold For Qualified Clients

What You Need To Know: Effective August 16, 2021, the Assets-Under-Management Test will increase to $1.1 million, and the Net Worth Test will increase to $2.2 million. On June 17, 2021, the U.S. Securities and...more

New Registration And Examination Requirements For New York Investment Adviser Representatives

Effective February 1, 2021, amendments to the New York Investment Advisory Act (the “Amendments”) require supervised persons representing certain New York-registered investment advisers, and, to a lesser degree, investment...more

SEC Modernizes Investment Adviser And Solicitor Marketing Rules

On December 22, 2020, the U.S. Securities and Exchange Commission (SEC) announced a modernized rule (the New Marketing Rule) governing (i) investment adviser advertisements and (ii) payments to solicitors. Under the...more

The SEC Identifies Common Investment Adviser Compliance Program Deficiencies Consistent With Deficiencies Recognized By Other...

On November 19, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert (the Risk Alert) identifying common compliance issues related to Rule 206(4)-7 (the...more

SEC Proposes Conditional Broker Exemption For Finders

What You Need To Know: •The SEC proposes to exempt two types of Finders from broker-dealer registration pursuant if they satisfy certain conditions. •Tier I Finders may provide potential investors’ contact information to...more

SEC Expands The Accredited Investor Definition

On August 26, 2020, the Securities and Exchange Commission (SEC) adopted amendments (the Amendment) to the “accredited investor” definition to broaden the category of potential investors in private offerings of securities...more

SEC Proposes To Amend Form 13F Reporting Thresholds For Institutional Investment Managers

On July 10, 2020, the Securities and Exchange Commission (SEC) proposed to raise the Form 13F reporting threshold for institutional investment managers from $100 million to $3.5 billion (the Proposal). Currently, investment...more

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