Videocast: Asset management regulation in 2020 videocast series – The ADV season
As discussed in our prior article, it's important to have a well-built foundation for your compliance program. But creating the program is just the start of the journey. Compliance is a journey requiring adaptation,...more
With Form ADV annual updating amendments due for many investment advisers by the end of next month, advisers should consider whether to update their proxy voting policies and related disclosure in Part 2A, Item 17 in light of...more
For most investment advisers, March signals the beginning of Form ADV season, where compliance officers gather all kinds of firm data to update a document fraught with potential regulatory liability. For the uninitiated, Form...more
As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more
As of January 1, 2024, the Beneficial Ownership Information Reporting Requirements (the “Reporting Rule”) issued by Financial Crimes Enforcement Network (“FinCEN”) to implement Section 6403 of the Corporate Transparency Act...more
On September 5, the U.S. Securities and Exchange Commission (SEC) announced enforcement actions against five investment advisers for violating Rule 206(4)-2 (the Custody Rule) and Rule 204-1(a) (the ADV Reporting Rule) of the...more
Private equity and hedge fund advisers continue to be subject to an increasing degree of supervision by the Securities and Exchange Commission (SEC) and other governmental agencies and self-regulatory organizations. The...more
This coming year will have a revamped ADV with some new requirements. A significant new consideration is the challenges that new cryptocurrencies and other digital assets present for investment advisers and their compliance...more
As summer recedes and we head into the autumn, investment advisers are in the home stretch of preparations for Form ADV reporting and disclosure changes that become effective October 1, 2017. The amendments, which were...more
David I. Osunkwo was a principal at Strategic Consulting Advisors, LLC, or SC Consulting. SC Consulting offered compliance consulting and CCO services to two SEC registered investment adviser firms under common control, Aegis...more
The Securities and Exchange Commission’s (SEC) Division of Investment Management recently modified its “Frequently Asked Questions on Form ADV and IARD,” adding several new topics and updating one existing item....more
Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more
On August 25, 2016, the SEC adopted Release No. IA-4509 (the “New Rule” or the “amendments”) that amends Form ADV to increase the amount of information that registered investment advisors (“Advisors”) must disclose to the...more
On August 25, the Securities and Exchange Commission (the SEC) adopted amendments to Form ADV Part 1 that will require SEC-registered investment advisers to provide a significant amount of new information. The SEC adopted...more
The Securities and Exchange Commission (“SEC”) adopted revisions to Part 1A of the Form ADV on August 25, 2016. All investment advisers registered with the SEC under the Investment Advisers Act of 1940, as amended (the...more
On August 25, 2016, the U.S. Securities and Exchange Commission (SEC) adopted numerous substantive and technical amendments to Form ADV, Part 1A, which previously had been proposed in a release dated May 20, 2015. Several of...more
On August 25, 2016, the Securities and Exchange Commission (“SEC”) modernized the reporting regime for investment advisers by adopting amendments to the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and...more
The SEC has adopted final rules requiring investment advisers to provide additional information on Form ADV and other matters. The final rules: - require information about an investment adviser’s separately managed...more
On May 20, 2015, the Securities and Exchange Commission (the “SEC”) proposed new rules, forms and amendments that would expand the information that registered investment advisers are required to report. The changes are...more
On May 20, 2015, the Securities and Exchange Commission (SEC) released several proposals, "Amendments to Form ADV and Investment Advisers Act Rules," that would require investment advisers to provide additional information on...more
On May 20, the Securities Exchange Commission proposed changes to rules affecting the reporting and disclosure obligations of registered investment companies and advisers. Investment Company Proposals: The SEC...more
On May 20, 2015, the Securities and Exchange Commission (SEC) unanimously approved a proposal of additional amendments to the Investment Advisers Act of 1940 (Advisers Act)1: specifically, three changes to Form ADV 1A, and...more