On February 21, 2013, the US Securities and Exchange Commission (the “SEC”) released its examination priorities for 2013. The priorities were published by National Examination Program (“NEP”), a program administered through...more
As a reminder, fund managers relying on the exemption from registration with the U.S. Commodity Futures Trading Commission (the "CFTC") set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more
The Massachusetts Securities Division ("the Division") is currently sending letters to exempt reporting advisers in Massachusetts ("MA ERAs") who manage private funds which rely on the exclusion from the definition of...more
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least annually (and best practice is...more