SEC Opens Registration for Investment Management Compliance Seminar
On December 8, 2011, the SEC announced that the national compliance seminar for CCOs and senior personnel at investment management firms is open for registration. The Compliance Outreach Program will be held on January 31, 2012, at the SEC’s headquarters … Read More
Rule 204A-1 Investment Adviser Code of Ethics
Nov. 2011
President Obama Proposes Taxing Carried Interest From Hedge Funds as Ordinary Income
President Obama recently announced a proposal to characterize income attributable to an investment manager’s carried interest (also referred to as an incentive allocation or performance fee) as ordinary income. The proposed re-characterization of carried interest income is part of the … Read More
Books and Records – How to Stay Ahead of the Curve
Aug. 2011
Proposed Revisions to California’s Custody Rule
The California Department of Corporations (“DOC”) recently issued an invitation for comments regarding proposed amendments to the California investment adviser custody rule, which sets forth requirements for investment advisers with custody or possession of clients’ funds or securities. Investment adviser … Read More
SEC Raises Dollar Amount Thresholds for Charging Performance Fees
On July 12, 2011, the SEC issued an order that raises the thresholds for whether investment advisers can charge performance fees to clients. The order was mandated by the Dodd-Frank Act, which required the SEC to adjust these dollar amount … Read More
Principal Trading Requirements for Investment Advisers
June 2011
Proposed Rule Would Increase SEC Oversight of Broker-Dealer Custody Practices
Rule 17a-5 under the Exchange Act requires broker-dealers to undergo an annual audit conducted by an independent public accountant and to file an annual report containing audited financial statements and certain supporting schedules with the SEC and the broker-dealer’s designated … Read More
Whistleblower Program Now Established
On May 25, 2011, the SEC adopted final rules establishing a whistleblower program pursuant to Section 922 of the Dodd-Frank Act. The final rules were approved by a narrow 3-2 vote by the five SEC commissioners, and are designed to … Read More