James H. Freis, Jr., Director of the Financial Crimes
Enforcement Network, let us know that his agency is working on anti-money
laundering requirements for investment advisers. At a November 15, 2011 speech
at the American Bankers Association/American...
The reorganization of the Division of Enforcement which
spawned the re-introduction of specialty groups was, in part, designed to focus
the resources of the Division and increase efficiency and effectiveness. Three
recently filed cases are an example...
Private Equity has been siting on the fringes of
Anti-money laundering regulation for many years. It's still illegal to be
involved in money laundering and fund managers should be taking some steps to
protect themselves and to identify problems...
Hedge funds were a key subject of debate during the passage of Dodd-Frank. While the funds were not tied to the causes of the market crisis, they do represent large pools of assets which can impact the market. Regulators frequently note that they have...
With the recent Iowa Straw Poll, the presidential
campaign season is getting into full gear. That also means that campaign fundraising
is in full gear. I thought it would be useful to apply the SEC's
new Pay-to-play for Investment Advisors to the...
When filling out Form ADV, Schedule A and Schedule B
require you to disclose control persons, owners, and significant indirect
owners of the investment adviser. The instructions call for the full legal
name: Last name, first name, and middle name....
Media used by Investment Advisers
There is a growing trend in the financial services
industry to use social media sites for outreach to existing as well as
potential customers. Noticing this trend, the Securities Division of The Office
With the impending
deadline for filing Form ADV to register as an investment adviser, you need
to jump through some hoops before you can do the filing. First step is visiting
the Investment Adviser Registration
Depository . Form ADV needs to be filed...
The results of coordinated state examinations of
investment advisers in the first half of 2011 by the North American Securities
Administrators Association (NASAA) reveal significant deficiencies in a
broad range of areas. As investment advisers gear...
by Cary J. Meer, Mark Mehrespand and Ben
On July 1, 2010, the Securities
and Exchange Commission (the "SEC" or "Commission") adopted
Rule 206(4)-5 (the "Rule") under the Investment Advisers Act...