California Proposes Exemption from Registration for Certain Advisers to Private Funds
On December 21, 2011, the California Corporations Commissioner released a notice of proposed rulemaking to create an exemption from the investment adviser registration requirements for advisers to certain private funds. California’s proposed exemption is in response to changes made by … Read More
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
Inadequate Compliance Programs Could Lead to Enforcement Actions & Penalties
In a recent press release, the SEC announced three enforcement actions against firms for failing to meet their obligations under Rule 206(4)-7 of the Advisers Act, commonly referred to as the “Compliance Program Rule.” Rule 206(4)-7 requires firms to (i) … Read More
Small Business Capital Formation Updates
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
Record-Setting Year for SEC Enforcement Actions
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
IARD System Updated to Reflect Changes to Form ADV Part 1A
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
SEC Adopts Form PF to Help Monitor Systemic Risk
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
California Issues Notice to Advisers Required to Transition from SEC to State Registration
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