On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more
9/10/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
FinCEN ,
Foreign Investment ,
Investment Adviser ,
Investment Management ,
Popular ,
Registered Investment Advisors ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
What is the purpose of the Corporate Transparency Act (“CTA”)?
Effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) imposed new federal reporting obligations on certain companies, including potentially...more
On August 23, 2023, the Securities and Exchange Commission (the “SEC”) approved by a 3-2 vote a final rule enacting a series of wide-sweeping changes to the regulation of the private funds industry (the “Final Rule”). While...more
8/25/2023
/ Compliance ,
Disclosure Requirements ,
Final Rules ,
Fund Managers ,
Investment ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Investors ,
Private Funds ,
Proposed Rules ,
Registered Investment Advisors ,
Regulatory Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On November 4, 2022, the U.S. Securities and Exchange Commission (the “SEC”) began enforcing its updated advertising requirements for federally registered advisers. Those rules, described in greater detail here, represented a...more
1/5/2023
/ Advertising ,
Investment ,
Investment Adviser ,
Marketing ,
New Guidance ,
New Rules ,
Policies and Procedures ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Solicitation ,
State and Local Government
On December 22, 2020, the U.S. Securities and Exchange Commission (“SEC”) announced that it was adopting amendments under the Advisers Act of 1940 (the “Advisers Act”) to implement a revised Rule 206(4)-1 (the “Marketing...more
All federally registered investment advisers and exempt reporting advisers are advised that in response to the disruptions resulting from COVID-19, the SEC has provided relief to allow affected advisers to extend the due date...more
As a reminder, Form ADV for registered advisers (Parts 1 and 2A) and Exempt Reporting Advisers (relevant portions of Part 1) must be updated within 90 days after the end of their fiscal year. For advisers with a fiscal year...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
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by December 18 in order to cover such fees. This deadline applies to the following...more
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