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Foley Hoag LLP

Fund Managers Must Assess Whether Microsoft/CrowdStrike Outage has Triggered Additional Form PF Filing

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The CrowdStrike computer failures that swept the globe on Friday, July 18, 2024, and persisted through the weekend may have impacted fund advisers relying on the Windows system, possibly triggering an “operations event” that...more

Foley Hoag LLP

Reminder: New Say-on-Pay Disclosures for Institutional Investment Managers Now Effective

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The Securities and Exchange Commission (“SEC”) adopted amendments to Form N-PX on November 2, 2022. Previously, Form N-PX applied solely to registered investment companies (i.e., mutual funds, exchange-traded funds and...more

Sullivan & Worcester

Deadline for Form 13F Filers for New Reporting Requirements on Executive Compensation Votes Rapidly Approaching

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The Securities and Exchange Commission adopted rule and form amendments that will require institutional investment managers who file Form 13F to use Form N-PX to report how they voted proxies on executive compensation (or...more

Goodwin

Form SHL: What You Need to Know

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The US Department of the Treasury (the Treasury), with the assistance of the Board of Governors of the Federal Reserve System and the Federal Reserve Bank of New York, conducts a mandatory benchmark survey every five years. ...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more

Seward & Kissel LLP

FinCEN's New Rule on Beneficial Ownership Information Reporting Requirements: Application to Investment Advisers and Related...

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January 1, 2024 is the effective date of a new rule (the “BOI Reporting Rule”) issued under the Corporate Transparency Act requiring domestic and foreign corporations, limited liability companies and other similar entities...more

Verrill

Private Clients Group Client Alert

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There have been a few important law and tax changes over the course of 2023 and we in the Private Clients Group here at Verrill wanted to make you aware of the recent changes, such as 1) new strict corporate reporting...more

Dorsey & Whitney LLP

Deadlines for 2024 IARD Renewal Program

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All SEC-registered investment advisers (“advisers”) are required to annually renew their state notice filings and state representative and branch registrations through the IARD Renewal Program. Preliminary renewal...more

Foley Hoag LLP

Reminder: Renewal and Notice Filing Fees for Investment Advisers due by December 11, 2023

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As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 11, 2023 in order to cover such fees (with a recommendation from...more

Morrison & Foerster LLP

U.S. SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the...more

McDermott Will & Emery

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the US Securities and Exchange Commission (SEC) adopted amendments to Sections 13(d) and 13(g) of the Securities Exchange Act of 1934, which among other things, accelerate the filing deadlines for...more

Seward & Kissel LLP

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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Who may be interested: Registered Investment Companies, Investment Advisers. Quick Take: The SEC adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Exchange...more

Vinson & Elkins LLP

Shorter Schedule 13D and Schedule 13G Filing Deadlines and New Guidance: SEC Adopts Final Rules Amending Beneficial Ownership...

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On October 10, 2023, the Securities and Exchange Commission (“SEC”) adopted amendments to the rules governing beneficial ownership1 reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the...more

Dorsey & Whitney LLP

RIA Regulatory Review - October 2023

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This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers. Please contact us with any questions on the topics covered below. The SEC Adopts Significant New Rules for Private...more

Seward & Kissel LLP

Memo to Clients 2023 - Annual Reminders

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This Memorandum is intended to remind you of certain U.S. annual requirements that may be applicable to your business and is divided into five sections. All investment advisers (whether or not registered with the Securities...more

Akin Gump Strauss Hauer & Feld LLP

A Transformation in SEC Regulation of Private Fund Managers

In recent weeks, the U.S. Securities and Exchange Commission (the “SEC”) has kicked off a wholesale transformation in the regulation of the private funds industry. These actions include rule proposals, enforcement actions,...more

Fenwick & West LLP

SEC Proposes Rules for Shorter Deadlines and More Transparency in Share Ownership Reporting

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On February 10, 2022, the U.S. Securities and Exchange Commission issued a proposal (Proposed rules: Modernization of Beneficial Ownership Reporting) that would amend Regulation 13D-G under the Securities Exchange Act of 1934...more

Foley & Lardner LLP

Form PF Changes Ahead – the SEC Keeps Its Focus on Private Fund Advisers

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On January 26, 2022, the Securities and Exchange Commission (“SEC”) voted 3-1 to propose amendments to Form PF. The Form PF, which was initially adopted in 2011 and became effective on June 15, 2012, is a confidential report...more

Morgan Lewis

FBAR Filing Deadline Extended for Certain Individuals

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Certain individuals who have only signature authority over non-US financial accounts now have until April 15, 2023 to file the Report of Foreign Bank and Financial Accounts....more

Foley Hoag LLP

Important Dates and Reminders For Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and...more

Proskauer - Tax Talks

Extension of FBAR Filing Deadline for Certain Filers

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On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain...more

Akin Gump Strauss Hauer & Feld LLP

Compliance Reminder: BE-180 Survey of Cross-Border Financial Services Transactions

U.S. persons who provided or received any financial services, such as investment advisory services, fund management or brokerage services, to or from non-U.S. persons during 2019 (“Reporters”) must file a Form BE-180 report...more

Proskauer Rose LLP

BE-180 Deadline Approaching for Certain Fund Managers

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Overview - The BE-180 report issued by the U.S. Commerce Department’s Bureau of Economic Analysis (the “BEA”) is a five-year benchmark survey that collects data on transactions between U.S. financial services providers...more

Foley Hoag LLP

Form CRS Due Date Reminder

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In accordance with SEC rules, all registered investment advisers with clients that are “retail investors” are required to file Part 3 of Form ADV (Form CRS) with the SEC, and deliver a current Form CRS to clients that are...more

Goodwin

Financial Services Weekly Roundup: OCC Finalizes New CRA Rule; Regulators Continue To Provide COVID-19-related Relief

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In This Issue. The Office of the Comptroller of the Currency (OCC) finalized a rule to strengthen and modernize regulations under the Community Reinvestment Act; the Securities and Exchange Commission (SEC) voted to adopt...more

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