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
Arizona Requires Proof of Lawful Presence in U.S. for IAR Registration
Arizona recently added a new documentation requirement for investment adviser representatives doing business in that state. Pursuant to Section 41-1080 of the Arizona Revised Statutes, Investment Adviser Representatives (IARs) must show they are U.S. citizens or in the United States … Read More
Financial Institutions Alert – The New SEC Whistleblower Program Takes Effect
On August 12, 2011, the SEC’s new whistleblower incentive program took effect. The program is designed to reward individuals who voluntarily provide the SEC with original information relating to possible violations of the securities laws that lead to a successful … Read More
News on the Horizon: Massachusetts Adopts Stringent Regulations
Last week, the Massachusetts Securities Division (the “Division”) adopted new regulations for investment advisers doing business within the State. This included legislation relating to the use of expert network firms and other paid consultants, limitations on investment advisers from receiving … Read More