Section 13(f) of the Securities Exchange Act of 1934 requires institutional investment managers with investment discretion over $100 million or more of certain equity securities to file quarterly reports disclosing their holdings using Form 13F. For purpose of Form 13F, … Read More
While it is no secret that most advisers to hedge funds and other private funds will be required to register with the SEC as investment advisers by March 30, 2012, less attention has been paid to the fact that some … Read More
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
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
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
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
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
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
As discussed in this prior post, the final deadline for previously exempt advisers (including advisers to hedge funds and private equity funds) to become registered with the SEC is March 30, 2012. The SEC is already showing signs that it … Read More