Core Compliance Blog Spotlight

OCIE Identifies Compliance Shortcomings Regarding Privacy Notices and Safeguard Policies (Regulation S-P)

Through their examination process, the Office of Compliance Inspections and Examinations (OCIE) has uncovered a number of compliance concerns pertaining to Regulation S-P, the Securities and Exchange Commission (SEC) regulation that defines requirements for privacy notices and safeguard policies... Read More
Core Compliance Blog Spotlight

Failure to Supervise Third Parties: AXA Advisors, LLC Sanctioned by FINRA

In early May, the Financial Industry Regulatory Authority (FINRA) announced fines levied against AXA Advisors, LLC (AXA), a company that sells and services group annuity contracts for employer-sponsored 401(k) retirement plans through an affiliated life insurance company. Read More

SEC Proposes New Family Office Definition Under Dodd-Frank Act

October 19, 2010

Currently, many “family offices” have been structured to take advantage of the exemption from registration under section 203(b)(3) of the Investment Advisers Act for any adviser that during the course of the preceding 12 months had fewer than 15 clients and neither held itself out to the public as...

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CCLS and the Latest Developments in the Financial Services Industry

October 18, 2010

As the regulatory and legal landscape applicable to the financial services industry continues to go through unprecedented changes, CCLS will stay on top of the latest developments and, through this page, provide updates and practical considerations for complying with the new laws and regulations....

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Delaware Supreme Court Holds that Hedge Funds Formed in Delaware May be Required to Disclose Names and Addresses of all Limited Partners Upon Request

October 11, 2010

The Delaware Revised Uniform Limited Partnership Act (“DRULPA”), under which many U.S. hedge funds are organized, entitles limited partners to access partnership information and records for purposes reasonably related to their interest as a limited partner, but DRULPA also provides the general...

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New CFTC Forex Rules to Take Effect Later This Month

October 04, 2010

The Commodity Futures Trading Commission (“CFTC”) has released final rules to drastically revise the regulatory structure pertaining to off-exchange retail foreign exchange (Forex) transactions, which are set to take effect on October 18, 2010. The adoption of the new rules is the latest effort by...

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SEC Announces Upcoming Plans to Implement New Registration, Reporting, and Recordkeeping Requirements for Investment Advisers

September 27, 2010

The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) includes significant changes to the registration and reporting requirements under the Investment Advisers Act of 1940 (the “Advisers Act”), including requiring many advisers to private funds to register with the...

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State of California to Accept Revised Form ADV Part 2

July 22, 2010

In July, the U.S. Securities & Exchange Commission (“SEC”) announced much anticipated revisions to Form ADV Part 2 (the “Disclosure Brochure”), requiring investment advisers to provide clients and prospective clients with narrative, “Plain English” disclosures of the adviser’s business practices,...

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