Did you know? 1. Compliance Rule 2. Disclosure 3. Fiduciary Duty 4. Code of Ethics 5. Advertising Rule 6. Custody Rule This fact was presented by the SEC’s Office of Compliance Inspections and Examinations’ (OCIE’s) assistant director, Renee … Read More ›
Form ADV On August 25, 2016, the Securities and Exchange Commission announced the adoption of amendments to the Investment Advisers Act of 1940 and Form ADV. Additional information on Form ADV will be required regarding separately managed accounts business, including … Read More ›
The SEC issued an order on June 14, 2016 approving inflation-related adjustments to the dollar amount tests in Rule 205-3 of the Investment Advisers Act of 1940. Under Rule 205-3, SEC-registered investment advisers are permitted to charge performance-based compensation to … Read More ›
On June 28, 2016, the SEC proposed a new rule that would require registered investment advisers to adopt and implement written business continuity and transition plans (Rule 206(4)-4 under the Investment Advisers Act of 1940). An adviser’s plan would be … Read More ›
On May 20th, 2015 the SEC proposed “…rules, forms, and amendments to modernize and enhance the reporting and disclosure of information by investment advisers and investment companies.” In plain English, that means more information reported to the SEC and the … Read More ›
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 ›
Q: Does Rule 204A-1 require reporting on company sponsored (or not sponsored, such as for a spouse) 401(k) plans if the asset type needs to be reported? To answer your question, first we will step back to the requirements. Rule … Read More ›
Q. Are Access Persons required to have all securities pre-cleared? A. Rule 204A-1 requires advisers to include, within their Code of Ethics, the requirement that all access persons obtain pre-clearance prior to purchasing any IPO or Private Placement. It does … Read More ›