Deadline Approaching: Tackling for Your Form ADV
The LawTV Video 9: Form ADV… Read More
Deadline Approaching: Considerations for Your Form ADV
For those firms with a fiscal-year end of December 31st, it is time once again to commence your Annual Amendments to Forms ADV.
SEC Releases Proposed Changes to Form 13F Report Requirements
On July 10, 2020, the U.S. Securities and Exchange Commission (“SEC”) released proposed changes to the rule requiring institutional managers to file Form 13F reports.
The changes include raising the reporting threshold from $100 million to $3.5 billion and eliminating the exclusion of smaller positions from the Form 13F report.
Immediate Impacts of COVID-19 on Investment Adviser Compliance Programs
A month ago, it was unclear of how much COVID-19 (the “coronavirus”) would impact all of us in every facet of our lives. For some, we are indefinitely “sheltered in” and are working remotely where possible. Others must take care … Read More
New Filing Requirement for Commodity Trading Advisors
The National Futures Association (“NFA”) announced its new quarterly filing requirement for commodity trading advisors (“CTAs”). The form is called NFA Form PR, and it requires CTAs to report to the NFA such information as general contact information, trading programs…
Keeping Up With Form 13F Requirements
The Securities and Exchange Commission (“SEC”) requires all institutional investment managers that use the U.S. mail (or other means of instrumentality of interstate commerce) in the course of their business, and whom exercise investment discretion on over $100 million…
SEC Proposes New Amendments to Regulation D in Light of Rule 506 Approval
On July 10 the Securities and Exchange Commission (“SEC”) amended Rule 506 of Regulation D to implement Section 201(a) of the Jumpstart Our Business Startups Act (the “JOBS Act”). The amendments to this Rule caused quite a stir in the…
BD Corner: SEC Approves FINRA Rule 5123 Requiring Filing of Private Placement Offering Docs
Last month FINRA announced SEC approval of new FINRA Rule 5123. The Rule requires each FINRA member firm selling securities in a private placement to file a copy of any private placement memorandum, term sheet or other offering documents with…
SEC Releases FAQs re: Form PF
On June 8, 2012 the SEC’s Division of Investment Management issued an initial set of frequently asked questions (FAQs) related to the filing of Form PF on the PFRD (Private Fund Reporting Depository). Investment advisers registered with the SEC and…
Large Traders Must Identify Themselves December 1st
On October 3, 2011, Rule 13h-1 went into effect which, among other things, requires “large traders” to begin identifying themselves to the SEC on December 1st by filing Form 13H. Under Rule 13h-1, a “large trader” is defined as a…