On February 9, 2012, the Commodity Futures Trading Commission (“CFTC”) issued “Final Rules” rescinding or amending certain exclusions and exemptions to registration as a commodity trading advisor (“CTA”); as well as expanding the definition of who is a CTA. Some … Read More
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
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
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
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
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