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Investment Advisers Act of 1940 Form ADV Investment Management

SEC Compliance Consultants, Inc. (SEC³)

Top Compliance Program Mistakes (and How to Avoid Them) (Part 2 of 2)

As discussed in our prior article, it's important to have a well-built foundation for your compliance program. But creating the program is just the start of the journey. Compliance is a journey requiring adaptation,...more

Sullivan & Worcester

SEC Proposes New Rule Requiring Investment Adviser Oversight of Certain Third Party Service Providers

Sullivan & Worcester on

On October 26, 2022, the Securities and Exchange Commission ("SEC") proposed a new rule under the Investment Advisers Act of 1940 ("Advisers Act") to prohibit registered investment advisers from outsourcing certain services...more

Proskauer Rose LLP

Regulation of Custodial Practices Under the Investment Advisers Act of 1940 Rule 206(4)-2: September 2020

Proskauer Rose LLP on

A. Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more

Ballard Spahr LLP

SEC Extends Conditional Relief Relaxing Deadlines under the Investment Company Act and Investment Advisers Act if Affected By...

Ballard Spahr LLP on

As discussed in our prior publication, on March 13, the Securities and Exchange Commission (SEC) issued two orders under the Investment Company Act of 1940 (the Investment Company Act) and the Investment Advisers Act of 1940...more

Herbert Smith Freehills Kramer

SEC Proposes to Modernize the Advertising and Cash Solicitation Rules for Investment Advisers

The Securities and Exchange Commission (the SEC) announced on Monday that it had voted to propose amendments to modernize Rule 206(4)-1 (which addresses investment adviser advertisements) (the Advertising Rule) and Rule...more

Perkins Coie

SEC Scrutiny of Advisers’ Share Class Selection, Revenue Sharing and Disclosure Practices Continues Apace

Perkins Coie on

Over the past several years, U.S. Securities and Exchange Commission (SEC) enforcement activity has eroded the stability of the once-standard lineup of share classes available to mutual fund investors. Starting with...more

Ballard Spahr LLP

OCIE Issues Risk Alert on Principal and Agency Cross-Trading Compliance Issues

Ballard Spahr LLP on

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert earlier this month from its national examination program warning investment advisers of the most common...more

Stinson - Corporate & Securities Law Blog

SEC Charges Chief Compliance Officer for Failure to Verify Information

David I. Osunkwo was a principal at Strategic Consulting Advisors, LLC, or SC Consulting. SC Consulting offered compliance consulting and CCO services to two SEC registered investment adviser firms under common control, Aegis...more

Ballard Spahr LLP

Investment Management Update

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SEC Issues Guidance on Mutual Fund Fee Structure - The Securities and Exchange Commission’s (SEC) Division of Investment Management recently issued a guidance update addressing disclosure issues and certain procedural...more

Ballard Spahr LLP

Investment Management Update

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Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Stinson - Corporate & Securities Law Blog

SEC Updates Form ADV

The SEC has adopted final rules requiring investment advisers to provide additional information on Form ADV and other matters. The final rules: - require information about an investment adviser’s separately managed...more

Ballard Spahr LLP

Investment Management Update - October 2015

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

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