After the Commodity Futures Trading Commission (“CFTC”) rescinded certain exemptions numerous advisers must now evaluate their registration requirements (please see our previous communiqués here on
After the Commodity Futures Trading Commission (“CFTC”) rescinded certain exemptions, numerous advisers must now evaluate their registration requirements (please see our previous communique here on the
After the Commodity Futures Trading Commission (“CFTC”) rescinded certain exemptions, numerous advisers must now evaluate their registration requirements (please see our previous communique here on the
Andrew Bowden, Deputy Director of the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) and in charge of OCIE’s national examination
New NFA Rules effective September 1, 2012 mandate the registration of “Swaps Firms” and “Swaps APs” and provide an exemption from Series 3 for Swap
The Securities and Exchange Commission (“SEC”) has proposed amendments to Rule 506 of Regulation D to allow the use of general solicitation and advertising in
The Private Investment Funds Subcommittee of the New York State Bar Association recently organized a meeting on the Securities and Exchange Commission’s (“SEC”) risk-based examination
How to Design an Appropriate Electronic Communications Review A frequent question we receive from both established and newly registered advisers concerns the proper review of
What would you ask the SEC? Clients and Friends: As you may know from our client alerts and website, we have been invited to
Adequate Supervision Section 203(e)(6) of the Investment Advisers Act of 1940 permits the SEC to bring an enforcement action against a registered investment adviser or
