Apparently, at a recent Investment Company Institute meeting, a member of the SEC’s Investment Management staff told the attendees that he reads the prohibitions in Section 17(e) of the Investment Company Act to be a zero tolerance policy prohibiting ALL … Read More ›
By: Jaqueline M. Hummel, Managing Director Hardin Compliance Consulting LLC May 12, 2015 At the end of April, many private fund managers considered many of their regulatory burdens met, including filing the annual amendment to Form ADV and Form … Read More ›
In April 2015, the SEC’s Division of Investment Management (“the Division”) issued a Guidance Update on Cybersecurity. The Update did not notify us of any impending rules or requirements, but did provide suggestions “that funds and advisers may wish to … Read More ›
The Securities and Exchange Commission announced the schedule for regional Compliance Outreach Program seminars for Investment Adviser and Investment Company Senior Officers. The seminars are sponsored by the SEC’s Office of Compliance Inspections and Examinations, Division of Investment Management, and … Read More ›