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
State Law versus Federal: Who will protect the CCO? We may not be the first to tell you, but it is important to note that
Private fund advisers that will be required to register with the Commodity Futures Trading Commission (“CFTC”) and become members of the National Futures Association (“NFA”)
The question on the minds of all new registrants. We now have the answer. Many should expect and prepare to be examined potentially this coming
