April Deadline Approaches for Firms Claiming GIPS Compliance
For firms that claim compliance with the Global Investment Performance Standards (GIPS), the 2010 edition of the GIPS standards must be adhered to when presenting a performance for periods after December 31, 2010. This means that come April, when many … Read More
Proposed Amendments to Net Worth Standard Under New Definition of Accredited Investor
Section 413(a) of the Dodd-Frank Act requires the definition of “accredited investor” under various SEC rules promulgated under the Securities Act of 1933 to exclude the value of a person’s primary residence for purposes of determining whether the person qualifies … Read More
SEC Proposes Private Fund Reporting Rule Requiring Significant Additional Disclosures by Private Fund Advisers
On January 25, 2011, the SEC proposed new Rule 204(b)–1 under the Advisers Act to require that SEC-registered investment advisers report systemic risk information to the SEC on Form PF if they advise one or more private funds. The information … Read More
SEC Study on Enhancing Investment Adviser Examinations Includes Possible Creation of SRO for Advisers
On January 19, 2011, the SEC submitted to Congress the much-anticipated Study on Enhancing Investment Adviser Examinations, as required by Section 914 of the Dodd-Frank Act. The Study gives Congress three options for improving the SEC’s examination program to address … Read More
EBSA Announces Public Hearing on Proposed Amendment to Definition of “Fiduciary” Under ERISA
As discussed in a prior Core Compliance blog posting, the U.S. Department of Labor (“DOL”) recently proposed significant amendments to the definition of “fiduciary” under the Employee Retirement Income Security Act of 1974 (“ERISA”). Due to the considerable attention and … Read More
SEC Announces Limited Time Extension for Preparation and Delivery of Form ADV Part 2B Brochure Supplements
The new Form ADV Part 2, which requires investment advisers to provide significant additional information about the firm and its supervised persons than was required by previous versions of the form, was adopted on July 28, 2010. The revised Form … Read More