Massachusetts Issues Guidance Regarding Use of Social Media by Investment Advisers
Recognizing the rapid growth of the use of social media in the securities industry, the SEC recently released a Risk Alert on the use of social media by investment advisers highlighting concerns that may arise from the use of social … Read More
SEC Adopts Revisions to Net Worth Test for Accredited Investor Definition to Exclude the Value of a Person’s Primary Residence
On December 21, 2011, the SEC adopted final rules to exclude the value of a person’s primary residence for purposes of determining whether the person qualifies as an “accredited investor” on the basis of having a net worth in excess … Read More
Compliance End-of-the-Year Checklist
Dec. 2011
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
Rule 204A-1 Investment Adviser Code of Ethics
Nov. 2011
