Introduction -

Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past year and a compliance calendar for the coming 12-month period.

Developments -

Although the Securities and Exchange Commission (SEC) has not adopted new rules targeted at investment advisers or typical private funds in 2014, the SEC and its staff have sent clear messages to investment advisers’ compliance departments through its new “broken window” approach to targeting small violations, sweep examinations and limited new guidance assisting investment managers with compliance obligations. Beyond investment adviser regulation, there have been substantial changes to tax reporting and withholding obligations and requirements for solicitation of investors in Europe.