On June 16th, the House Financial Services Committee approved H.R. 5424, the “Investment Advisers Modernization Act of 2016.” The proposed bill primarily provides relief to private fund advisers, but also includes provisions applicable to investment advisers that don’t manage private … Read More
On April 25, 2016, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management issued a no-action letter to the Investment Adviser Association (“IAA Letter”) giving relief to certain sub-advisers from surprise audits requirements under Rule 206(4)-2 under the Investment … Read More
The Securities and Exchange Commission (SEC) rounded out a busy month of issuing enforcement actions by charging three investment advisory (IA) firms with violations of Section 206(4) and Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”). … Read More
On July 31, 2013, the world of broker-dealers (BDs) was taken on by the Securities and Exchange Commission (SEC) with the passage of a new rule and a set of new amendments affecting this financial sphere. While each of these … Read More
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
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
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
