Ongoing Compliance Concerns with Social Media Use
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Rule 206(4)-1 under the Investment Advisers Act of 1940 prohibits any investment adviser (“IA”) from directly or indirectly publishing, circulating or distributing any advertisement that: (i) contains or refers to a testimonial regarding the IA or past recommendations of such … Read More

CFTC’s final rule regarding de minimis exemption from registration
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On February 8, 2012, the Commodity Futures Trading Commission (“CFTC” or “Commission”) put forth final regulations repealing the popular exemption from registration for private fund managers under CFTC Regulation 4.13(a)(4) (exemption for commodity pool operator) and 4.13(a)(8) (exemption for commodity … Read More

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