News & Analysis as of

Separately Managed Accounts (SMA)

Lowenstein Sandler LLP

SEC Settlement Reflects Continued Scrutiny Regarding Conflicts and Preferential Treatment

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On May 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (Adviser) that found the Adviser had (a) failed to adequately disclose conflicts pertaining to...more

Kilpatrick

Mind your P’s and P’s – SEC Settles Enforcement Action Related to ESG Policies and Procedures

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The Securities and Exchange Commission (the “SEC”) has again set its sights on registrants’ environmental, social, and governance (“ESG”)-related investing. In another major action against registrants involving ESG-related...more

Cadwalader, Wickersham & Taft LLP

SMArt Due Diligence - April 2022 | Issue No. 171 - Due Diligence on Public Funds in Funds-of-One

Fund Finance Friday has previously reported on the continuous rise of public pension money in private equity. Generally, such investments are made in commingled funds with a diversified group of investors, but we also...more

Dorsey & Whitney LLP

What Lies Ahead? Q1 2018 Investment Management Regulatory Updates and Reminders

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As we start the New Year, we would like to remind our clients of certain regulatory developments and upcoming deadlines for Q1 2018. New Form ADV - The new Form ADV takes a deeper dive by requiring additional...more

Pullman & Comley, LLC

Changes to Form ADV Just in Time for Annual Updating Amendments

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It is that time of year again, when state and federal registered investment advisers (RIAs) renew their registrations and file annual Form ADV updating amendments. The updating amendments are due by March 31, 2018. Part 1A...more

Troutman Pepper

A Strategic Approach To Launching A New Fund

Troutman Pepper on

Many managers have portable track records from prior firms that they can legally use to market their new funds. This means that the manager owns the rights to the supporting data and that the strategy and decision-makers are...more

Winstead PC

Investment Adviser Compliance with SEC’s Amended Form ADV

Winstead PC on

Beginning October 1, 2017, investment advisers filing Form ADV with the Securities and Exchange Commission (the “SEC”) must file using the amended form adopted by the SEC on August 25, 2016 (the “Amended Form ADV”). According...more

Dorsey & Whitney LLP

Countdown to New Form ADV – Are You Ready?

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October 1st is less than a month away. That’s the effective date for the new Form ADV (Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers). ...more

Foley Hoag LLP

SEC Adopts Rules to Enhance Adviser Reporting

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Recently enacted SEC rules have imposed several amendments to Form ADV that advisers should be aware of, and which will apply to all Form ADVs filed after September 31, 2017 (for most advisers with a December 31-year end, the...more

Dechert LLP

SEC Form ADV SMA Amendments and Investment Adviser Recordkeeping Rules: Compliance Deadline Quickly Approaching

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The October 1, 2017 compliance date for the amendments to Form ADV and to rule 204-2 (Recordkeeping Rule), as well as technical amendments to other rules under the Investment Advisers Act of 1940 (Advisers Act) (collectively,...more

Broker-Dealer Compliance + Regulation

SEC Staff Discusses Current Initiatives Related to Investment Advisers at SEC Speaks in 2017 Conference

On February 24, 2017, the U.S. Securities and Exchange Commission’s Division of Investment Management (the “Staff”) participated in a panel at the Practising Law Institute’s SEC Speaks in 2017 conference. As part of the...more

K&L Gates LLP

SEC Adopts Rules for Reporting Separately Managed Accounts on Form ADV and Revised Recordkeeping Rules

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Amendments to Form ADV - Information Regarding Separately Managed Accounts - The SEC’s final amendments to Part 1A of Form ADV include items intended to collect more information about each adviser’s SMAs. The...more

Eversheds Sutherland (US) LLP

SEC Adopts Changes to Form ADV and Books and Records Rules

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

BCLP

SEC Adopts Revisions to Form ADV Part 1A and Advisers Act

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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

Katten Muchin Rosenman LLP

Significant Changes to Form ADV and Performance Advertising Rules Adopted

On August 25, the Securities and Exchange Commission (SEC) adopted amendments to Form ADV and to certain rules promulgated under the Investment Adviser Act of 1940, as amended (the "Advisers Act"). These amendments will be...more

A&O Shearman

SEC Adopts New Disclosure and Recordkeeping Requirements for Investment Advisers

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In May 2015, we reported on proposals by the Securities and Exchange Commission to expand public disclosures by registered investment advisers (“RIAs”) of various aspects of their separately managed accounts (“SMA”)...more

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