On December 21, 2011, the SEC adopted final rules to exclude the value of a person’s primary residence for purposes of determining whether the person qualifies as an “accredited investor” on the basis of having a net worth in excess … Read More
On December 21, 2011, the California Corporations Commissioner released a notice of proposed rulemaking to create an exemption from the investment adviser registration requirements for advisers to certain private funds. California’s proposed exemption is in response to changes made by … Read More
On December 8, 2011, the SEC announced that the national compliance seminar for CCOs and senior personnel at investment management firms is open for registration. The Compliance Outreach Program will be held on January 31, 2012, at the SEC’s headquarters … Read More
In a recent press release, the SEC announced three enforcement actions against firms for failing to meet their obligations under Rule 206(4)-7 of the Advisers Act, commonly referred to as the “Compliance Program Rule.” Rule 206(4)-7 requires firms to (i) … Read More
The SEC’s annual Government-Business Forum on Small Business Capital Formation is sure to focus heavily on various means to remove current legislative and regulatory burdens on the ability to raise capital. I attended last year’s Forum, which focused on many … Read More
On November 9, 2011, the SEC issued a press release announcing that the SEC filed a total of 735 enforcement actions in its fiscal year ending September 30, the most ever in a single year in SEC history. More than … Read More
As discussed in this previous Compliance Corner post, the SEC recently amended Form ADV Part 1A to incorporate numerous changes to the registration, reporting, and recordkeeping requirements imposed by the Dodd-Frank Act. The IARD system has now been updated to … Read More