SEC Considers Extension of Compliance Dates for Investment Adviser Registration and Deregistration Requirements Under Dodd-Frank
On Friday, April 8, 2011, the Associate Director of the SEC’s Division of Investment Management, Robert E. Plaze, issued a letter to the President of the North American Securities Administrators Association (NASAA), indicating that the SEC will likely grant additional … Read More
Will Private Fund Managers Have to Register Yet Again?
Currently, Rules 4.13(a)(3) and 4.13(a)(4), which were adopted by the Commodity Futures Trading Commission (“CFTC”), provide exemptions from registration as a Commodity Pool Operator (“CPO”) for managers of certain private funds provided that the private funds either: (i) limit their … Read More
Division of Investment Management Releases Responses to Questions About the Pay to Play Rule and Part 2 of Form ADV
Two of the more significant final rules adopted by the SEC over the past year were the new “pay to play” rule adopted on July 1, 2010, and the amendments to Part 2 of Form ADV adopted on July 28, … Read More
SEC Proposes Private Fund Reporting Rule Requiring Significant Additional Disclosures by Private Fund Advisers
On January 25, 2011, the SEC proposed new Rule 204(b)–1 under the Advisers Act to require that SEC-registered investment advisers report systemic risk information to the SEC on Form PF if they advise one or more private funds. The information … Read More
SEC Announces Limited Time Extension for Preparation and Delivery of Form ADV Part 2B Brochure Supplements
The new Form ADV Part 2, which requires investment advisers to provide significant additional information about the firm and its supervised persons than was required by previous versions of the form, was adopted on July 28, 2010. The revised Form … Read More
Looking Ahead: Compliance Considerations for 2011
As 2010 comes to an end, firms should be aware of several important considerations with regard to their compliance programs. Investment advisers with a fiscal yearend of December 31 must file annual updates to Form ADV no later than March … Read More
SEC Releases Proposed Exemptions From Registration Under the Investment Advisers Act of 1940
As mentioned in last week’s post, the SEC on November 19, 2010, released proposed rules and rule amendments implementing various provisions of Title IV of the Dodd-Frank Act. The first release includes proposed amendments to various rules and forms in … Read More
SEC Releases Proposed Rules Implementing Amendments to Investment Advisers Act of 1940
On November 19, 2010, the SEC released two separate but related releases proposing new rules and rule amendments governing the registration of investment advisers with the SEC (and exemptions therefrom) to give effect to provisions of Title IV of the … Read More
SEC Small Business Forum on Capital Formation Meets to Develop Recommendations Regarding Implementation of Dodd-Frank Act
On Thursday, November 18, 2010, Core Compliance had the opportunity to participate in the SEC’s 29th Annual Small Business Forum on Capital Formation. The event is designed to give members of the small business community and their advocates the opportunity … Read More