Nov/Dec. 2011

The SEC’s annual Government-Business Forum on Small Business Capital Formation is sure to focus heavily on various means to remove current legislative and regulatory burdens on the ability to raise capital. I attended last year’s Forum, which focused on many … Read More

Nov. 2011

On November 9, 2011, the SEC issued a press release announcing that the SEC filed a total of 735 enforcement actions in its fiscal year ending September 30, the most ever in a single year in SEC history. More than … Read More

As discussed in this previous Compliance Corner post, the SEC recently amended Form ADV Part 1A to incorporate numerous changes to the registration, reporting, and recordkeeping requirements imposed by the Dodd-Frank Act. The IARD system has now been updated to … Read More

On October 26, 2011, the SEC unanimously adopted new Rule 204(b)-1 under the Advisers Act, which requires all SEC-registered investment advisers with at least $150 million in private fund assets under management to report systemic risk information to the SEC … Read More

SEC-registered investment advisers with assets under management between $25 million and $100 million will generally be required to transition to state registration under the Dodd-Frank Act. Using information obtained from IARD, the California Department of Corporations issued a notice to … Read More

On September 15th, Rep. McCarthy (R-CA) introduced HR 2940, the Access to Capital for Job Creators Act which, if passed, would remove the prohibition on general solicitation under Rule 506 of Regulation D. The bill is designed to increase the … Read More

As discussed in this prior post, the final deadline for previously exempt advisers (including advisers to hedge funds and private equity funds) to become registered with the SEC is March 30, 2012.  The SEC is already showing signs that it … Read More

Sept. 2011