On June 4, 2019, the Securities and Exchange Commission (“SEC”) announced that Deer Park Road Management Company, LP (“Deer Park”), a prominent private fund manager in the mortgage-backed securities space and registered...more
Investment Advisers -
Annual Compliance Reviews -
All investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 17 in order to cover such fees (with a recommendation from IARD to...more
On October 31, 2018, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a Risk Alert summarizing the most common deficiencies relating to Rule 206(4)-3 (the “Cash...more
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) recently released a Risk Alert summarizing the most frequent compliance issues relating to fees and expenses from over 1,500...more
Investment Advisers-
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission ("SEC") or The Commonwealth of Massachusetts are required to review their compliance...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 18 in order to cover such fees (with a recommendation from IARD to...more
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
Investment Advisers -
Annual Compliance Reviews -
All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their compliance...more
2/3/2017
/ Bad Actors ,
CFTC ,
Commodity Pool ,
Confidentiality Policies ,
Cybersecurity ,
Data Privacy ,
Exempt Reporting Advisers (ERAs) ,
FATCA ,
FBAR ,
Financial Statements ,
Form 13F ,
Form ADV ,
Form PF ,
Form PQR ,
Investment Adviser ,
Pay-To-Play ,
Privacy Policy ,
Rule 506 ,
Securities and Exchange Commission (SEC)
As noted in a previous alert, the Securities and Exchange Commission has now issued an Order, effective as of August 15, 2016 (the "Effective Date"), which amends SEC Rule 205-3 (the “Performance Fee Rule”) under the...more
On May 24, 2016, the Securities and Exchange Commission published in the Federal Register a notice of the Commission’s intent to issue an order (the “Proposed Order”) amending SEC Rule 205-3 (the “Performance Fee Rule”) under...more
Under the SEC Rule 206(4)-2, the “custody rule,” registered investment advisers with custody of client funds or securities are required to take a number of steps designed to safeguard those client assets. One such step is...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by December 18 in order to cover such fees. This deadline applies to the following...more
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more
9/11/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CIP ,
Comment Period ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Internal Controls ,
Investment Adviser ,
Policies and Procedures ,
Proposed Regulation ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Training
Under Rule 204A-1 of the Investment Advisers Act of 1940, a registered investment adviser’s written code of ethics must include requirements for reporting of personal securities holdings and trading activity by the adviser’s...more
On May 20, 2015, the SEC announced proposals to modify and increase the amount of information that it collects from investment companies (“ICs”) and investment advisers (“IAs”) and to create new rules that impose additional...more
On April 28, 2015, the SEC’s Division of Investment Management (the “Division”) issued a Guidance Update regarding the SEC’s initiative to assess cybersecurity preparedness and threats in the securities industry, further...more
Investment Advisers -
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...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must fund their IARD accounts by December 12 in order to cover such fees. This deadline applies to the following...more
Investment Advisers -
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...more
Under SEC Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”), an SEC registered investment adviser is permitted to enter into an engagement that includes an incentive compensation component, provided...more
On August 27, 2013, the Office of Compliance Inspections and Examinations of the Securities and Exchange Commission (the “SEC”) issued a National Exam Program Risk Alert (the “Risk Alert”) resulting from its review of the...more
Following the adoption of the Dodd-Frank Act and amendments to the rules under the Investment Advisers Act of 1940 (the “Advisers Act”) adopted by the SEC, many previously unregistered managers to private funds, including...more
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