On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that will define most SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) as...more
10/16/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
FinCEN ,
Foreign Private Issuers ,
Investment Advisers Act of 1940 ,
Money Laundering ,
Mutual Funds ,
Policies and Procedures ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Travel Rule
SEC Chairman Jay Clayton recently noted that: “Many small businesses face difficulties raising the capital they need to grow and thrive . . . [and] finders may play an important role in facilitating capital formation for...more
10/12/2020
/ Accredited Investors ,
Broker-Dealer ,
Capital Formation ,
Capital Raising ,
Comment Period ,
Finders ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Small Business ,
Small Offering Exemptions
On August 26, 2020, the SEC adopted several changes to expand the definition of an “accredited investor.” For the first time, a new category will enable natural persons to qualify as accredited investors based upon their...more
On April 16, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert summarizing numerous issues it found in its recent examinations of SEC-registered...more
5/2/2019
/ Broker-Dealer ,
Customer Privacy ,
Data Privacy ,
Data Protection ,
Enforcement Actions ,
Investor Protection ,
OCIE ,
Personally Identifiable Information ,
Privacy Notice Rule ,
Registered Investment Advisors ,
Regulation S-P ,
Risk Alert ,
Securities and Exchange Commission (SEC)
Effective August 15, 2016, the net worth threshold for qualified clients under Rule 205-3 is increased from $2 million to $2.1 million.
If you have advisory agreements or subscription agreements that require a client or...more
On June 1, 2016, the SEC sent a warning to general partners of private investment funds (including private equity funds, hedge funds, venture capital funds and leveraged buyout funds) by entering into a settlement agreement...more