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States Toughening Up and Cracking Down on RIAs
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In 2012, states expanded their oversight of registered investment advisers (“RIAs”) from those with $25 million in assets, to those with $100 million or less.  Prior to 2012, the Securities and Exchange Commission (“SEC”) had been responsible for overseeing these…

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States Weigh In on Identity Theft Protections
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In April 2013, the SEC and the CFTC jointly issued their final rules and guidelines for entities regulated by each of the respective agencies under Regulation S-ID – Identity Theft Red Flags Rules (the “Rule” or “Regulation S-ID”).  The new…

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New Filing Requirement for Commodity Trading Advisors
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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…

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“Harmonization Rules” Provide Relief For Dually Registered Operators
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Recently, the Commodity Futures Trading Commission (“CFTC”) adopted final rules (the “Harmonization Rules”) amending the compliance requirements for operators of investment companies (“RICs”) registered with the Securities and Exchange Commissions (“SEC”), who are also subject to registration as commodity pool…

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Anti-Money Laundering Regulations for IAs
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The stability of our financial economy can be deeply affected by the act of money laundering.  Anti-Money Laundering (“AML”) programs for financial institutions are governed by various laws, including the Bank Secrecy Act of 1970 (“BSA”), the Money Laundering Control…

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