News & Analysis as of

Investment Adviser Exemptions Reporting Requirements

Foley Hoag LLP

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

Foley Hoag LLP on

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

Akin Gump Strauss Hauer & Feld LLP

Update (2): The NY LLC Transparency Act and Corporate Transparency Act’s Impact on Private Fund Managers

In the weeks since publishing our original alert, FinCEN released several frequently asked questions (FAQs) on the application of the Corporate Transparency Act (CTA). Private fund managers are likely to find two of these...more

The Rodman Law Group, LLC

The Corporate Transparency Act Reporting Exemptions

The Corporate Transparency Act mandates certain reporting requirements for beneficial ownership information for certain companies, with the goal of preventing the illicit use of anonymous shell companies for financial crimes....more

K&L Gates LLP

The US Corporate Transparency Act: Practical Considerations for Private Fund Sponsors as the Effective Date Approaches

K&L Gates LLP on

Earlier this year, the US Congress passed the Corporate Transparency Act (CTA). The CTA will require thousands of privately held US and non-US entities to report beneficial ownership to the US Treasury Department’s Financial...more

Seward & Kissel LLP

FinCEN Imposes New Reporting Requirements on LLCs and Other Entities

Seward & Kissel LLP on

The Corporate Transparency Act (the “CTA”), a set of new regulations being implemented by the Financial Crimes Enforcement Network (“FinCEN”), requires entities newly formed or registered to do business in the United States...more

Mintz Edge

FinCen Publishes Final Rule on Beneficial Ownership Requirements - a Critical Step Towards Heightened Transparency in U.S....

Mintz Edge on

On January 1, 2021, Congress passed the Corporate Transparency Act (“CTA” or the “Act”) to “better enable critical national security, intelligence and law enforcement efforts to counter money laundering, financing of...more

A&O Shearman

UPDATED: SEC Extends Sweeping Temporary Exemptions Granted to Funds to Comply with Voting, Reporting and Prospectus Delivery...

A&O Shearman on

In an Order dated March 25, 2020, the Securities and Exchange Commission extended the exemptions offered to investment companies, business development companies (BDCs) and investment advisers grappling with challenges to the...more

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Dechert LLP

OCIE Extends Exams to Exempt Reporting Advisers

Dechert LLP on

Marc Wyatt, Director of the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE), indicated on November 20, 2015 that the OCIE staff is now examining “Exempt Reporting Advisers”...more

Morgan Lewis

CFTC Staff Exempts Certain Commodity Trading Advisors from Form CTA-PR Reporting

Morgan Lewis on

The reporting relief applies to commodity trading advisors that do not “direct” trading of any client commodity interest trading accounts. On July 23, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued...more

Broker-Dealer Compliance + Regulation

Year-End CFTC Reporting Requirements for Fund Advisers

The National Futures Association (NFA) reminded fund advisers claiming an exemption from registering as a commodity pool operator (CPO) that they must confirm by March 3, 2014 that will continue to rely on the exemption....more

Broker-Dealer Compliance + Regulation

SEC Staff Elaborates on Venture Capital Adviser Exemption

The SEC’s Division of Investment Management provided advisers to venture capital funds with guidance on fund structures that do not jeopardize an adviser’s ability to rely on the exemption from registration provided by...more

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