Understanding SEC Rule 204A-1 and Code of Ethics Requirements
In July 2004, the SEC adopted Rule 204A-1 of the Investment Advisers Act of 1940 to require federally-registered investment advisers to adopt a Code of Ethics to address not only personal trading, but to also adopt standards of business conduct, … Read More
News on the Horizon: Massachusetts Adopts Stringent Regulations
Last week, the Massachusetts Securities Division (the “Division”) adopted new regulations for investment advisers doing business within the State. This included legislation relating to the use of expert network firms and other paid consultants, limitations on investment advisers from receiving … Read More
California RIA Registration Requirements: A Step-by-Step Guide
If your firm advises clients from an office in California — or has more than a handful of California clients — you likely need to register as an investment adviser with the California Department of Financial Protection and Innovation (DFPI). … Read More
States on the Move to Revise IA Registration
Over the past few months, several states have commenced the process of adopting revised investment adviser registration requirements and new exemptions. These changes are based on the increase in the assets under the management threshold for SEC registration and the … Read More
SEC Considers Extension of Compliance Dates for Investment Adviser Registration and Deregistration Requirements Under Dodd-Frank
On Friday, April 8, 2011, the Associate Director of the SEC’s Division of Investment Management, Robert E. Plaze, issued a letter to the President of the North American Securities Administrators Association (NASAA), indicating that the SEC will likely grant additional … Read More
SEC Announces Upcoming Plans to Implement New Registration, Reporting, and Recordkeeping Requirements for Investment Advisers
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 … Read More