New Requirements for Certain Broker-Dealer Operations Personnel on the Horizon
PostApril 2011
The Investment Adviser Section of the North American Securities Administrators Association (NASAA) recently released proposed changes to the NASAA model investment adviser custody rule. The most controversial aspect of the model rule, as originally proposed, was the requirement that advisers … 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
Although the SEC would maintain some functionality in the event of a government shutdown, the majority of its activities, including inspections and examinations of registered investment advisers and broker-dealers would and ongoing enforcement actions would be discontinued until after a … Read More
Currently, Rules 4.13(a)(3) and 4.13(a)(4), which were adopted by the Commodity Futures Trading Commission (“CFTC”), provide exemptions from registration as a Commodity Pool Operator (“CPO”) for managers of certain private funds provided that the private funds either: (i) limit their … Read More
Two of the more significant final rules adopted by the SEC over the past year were the new “pay to play” rule adopted on July 1, 2010, and the amendments to Part 2 of Form ADV adopted on July 28, … Read More
For firms that claim compliance with the Global Investment Performance Standards (GIPS), the 2010 edition of the GIPS standards must be adhered to when presenting a performance for periods after December 31, 2010. This means that come April, when many … Read More
Section 413(a) of the Dodd-Frank Act requires the definition of “accredited investor” under various SEC rules promulgated under the Securities Act of 1933 to exclude the value of a person’s primary residence for purposes of determining whether the person qualifies … Read More