Guidance Through SEC Regulations Governing Family Office Services
Under the Dodd-Frank Act, promulgated on July 21, 2010, the Securities and Exchange Commission (SEC) requires that certain advisers providing family office counsel services register as investment advisers if certain exemptions are not met. Under these new SEC guidelines, persons who are managing money for high-asset families, or are otherwise providing financial advice may need to register. Prior to the Dodd-Frank Act, many family office service advisers could be exempt from registration if they advised fewer than 15 clients. However, this exemption has been repealed in order to allow for greater regulatory oversight.
The securities lawyers and professionals at Jacko Law Group, PC (“JLG”), can answer your questions and guide you through the SEC regulations governing family office services. We will review your particular situation and analyze whether you are exempted from registration or required to register as an investment adviser with the SEC. Our firm will consider, among other things, the types of services provided and for whom, as well as whether you are marketing your services.
We will examine the specifics of your circumstance in order to provide you with accurate and detailed counsel. If registration is required, JLG can assist with all Form ADV filings and on-going corporate counsel on family office regulatory compliance requirements.
We can assist your family office by:
- Authoring your advisory contracts
- Creating & maintaining compliance programs
- Developing written policies, procedures & internal controls
- Testing of AML, BCP & Reg S-P programs
- Reviewing ERISA compliance requirements
- Performing Advertising Reviews