Important news out of the SEC this week for investment advisers who are now registering or filing reports as exempt reporting advisers (ERAs) courtesy of the new Dodd-Frank requirements. The SEC posted a new FAQs on its website regarding Form ADV... Read More
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.... Read More
Social 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 of... Read More
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... Read More
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... Read More
by Cary J. Meer, Mark Mehrespand and Ben Jacqmotte Excerpt: 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... Read More
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... Read More
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... Read More
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... Read More
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... Read More
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... Read More