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
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
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
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
As 2010 comes to an end, firms should be aware of several important considerations with regard to their compliance programs. Investment advisers with a fiscal yearend of December 31 must file annual updates to Form ADV no later than March … Read More
As mentioned in last week’s post, the SEC on November 19, 2010, released proposed rules and rule amendments implementing various provisions of Title IV of the Dodd-Frank Act. The first release includes proposed amendments to various rules and forms in … Read More
On November 19, 2010, the SEC released two separate but related releases proposing new rules and rule amendments governing the registration of investment advisers with the SEC (and exemptions therefrom) to give effect to provisions of Title IV of the … Read More
On Thursday, November 18, 2010, Core Compliance had the opportunity to participate in the SEC’s 29th Annual Small Business Forum on Capital Formation. The event is designed to give members of the small business community and their advocates the opportunity … Read More
The Department of Labor has published a proposed rule that would amend the definition of “fiduciary” and would significantly expand the categories of persons who would be deemed to be fiduciaries subject to the Employee Retirement Income Security Act of … Read More
Under Rule 206(4)-2 of the Advisers Act (the “Custody Rule”), investment advisers to one or more private funds are deemed to have custody of the assets in the fund and accordingly must implement certain procedures designed to protect those assets … Read More