by admin | Sep 17, 2024 | FinCEN, Investment Advisers
I. Overview On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a new Final Rule (the “AML Rule”) imposing anti-money laundering (“AML”) obligations on certain investment advisers who are either registered with the Securities and Exchange...
by admin | Sep 4, 2023 | Compliance, Custody Rule, Investment Adviser Registration, Investment Advisers, SEC
On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”) implemented heavily anticipated private fund reforms (the “Private Funds Rules” or the “Rules”) promulgated under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Although the...
by admin | Jul 5, 2017 | Investment Advisers, Investment Funds
By Simon Riveles Broadened Scope of ERISA Fiduciary Rules After several years of debate and revision, a Department of Labor (DOL) regulation, revising the definition of a “fiduciary” as it applied to investment managers, became applicable on June 9, 2017. The new...
by admin | Oct 5, 2016 | Investment Advisers
By Greg Caramenico and Lauren Mack On August 18th, the Securities and Exchange Commission (“SEC”) approved a Financial Industry Regulatory Authority Inc. (“FINRA”) rule that establishes less burdensome regulations for “Capital Acquisition Brokers” (“CABs”), which are...
by admin | Jun 6, 2016 | Investment Advisers, Investment Funds
By William Kelly and Simon Riveles On May 24, 2016, the Securities and Exchange Commission (“SEC”) published a notice of its intent to issue an order increasing the net worth threshold for “qualified clients,” as defined in Rule 205-3 under the Investment Advisers Act...
by admin | Nov 16, 2015 | Investment Advisers
By William Kelly Acknowledging the rapid evolution of information technology and correspondent threats, on August 20, 2015 the National Futures Association (“NFA”) issued an Interpretive Notice addressing cybersecurity concerns. The Interpretive Notice established...
