Below is a press release on the investment adviser registration presentation we developed to help fund managers with the SEC registration requirements. **** Investment Adviser Registration Presentation for Fund Managers Released by Cole-Frieman & Mallon LLP March 30, 2012 Deadline for SEC Registration Approaches SAN FRANCISCO, CA – January 25, 2012 [...]
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Investment Adviser Registration Presentation for Fund Managers
California Proposes Private Fund Adviser Exemption
Hedge Fund Managers Exempt from Registration in California As a general proposition, managers who are located in California must register as an investment adviser if they are providing investment advice for compensation. There are exemptions from the registration requirement which we have detailed previously. Because of the changes in the [...]
Revised Form ADV Part 1 Now Available on IARD
New Questions Added to Form ADV Part 1 The SEC has released a new Form ADV Part 1a which includes a number of additions as described in greater depth below. Please also see the the paper version of the new Form ADV Part 1 which is currently effective. Since enactment of the Dodd-Frank [...]
SEC Action Against Hedge Fund Manager for Marketing Misrepresentations
SEC v. Andrey C. Hicks and Locust Offshore Management, LLC Marketing, of course, is an issue close to the heart of every hedge fund manager. You spend so much time and effort making your pitchbook and other materials exactly right in terms of strategy, investment process and all the details [...]
Investment Adviser and IA Representative Registration Renewal 2012
If your firm is registered as an investment adviser (IA) then you may have received notice from FINRA to renew your firm’s registration for 2012. If you have not received the notice or have not paid the renewal fees, the following provides an overview of the process. Background IA firms [...]
California’s Hedge Fund “Pay to Play” Laws Updated
New Lobbyist Requirements Apply to Hedge Fund Placement Agents With the enactment of AB 1743 (effective January 1, 2011) and SB 398 (effective October 9, 2011), California has imposed new requirements on persons who market investment managers and their funds to California pension plans – that is, California Public Employees’ [...]
NASAA Examination of IA Compliance Deficiencies
Examination Reveals Compliance Focus Areas NASAA, the lobbying body of the various state securities divisions, recently released a set of examination findings which describe the common compliance deficiency areas for IA firms registered with the state securities commissions. The exams, which were completed by state administrators, showcase a number of [...]
Connecticut Issues Orders Regarding Investment Adviser Registration
Three Orders Focused on New Hedge Fund Regulations On June 11, 2011, Connecticut Department of Banking issued three orders relating to Connecticut investment adviser registration requirements in response to the SEC issuing final hedge fund registration regulations required by the Dodd-Frank Act. The orders (1) create a registration transition period for [...]
Arizona IA Representative Documentation Requirement
Arizona Hedge Fund Manager Documentation Requirements Increase In addition to increased requirements under the Dodd-Frank Act, various states are increasing requirements for state registered investment advisers and their representatives. Many regulations are going to be based on the prevailing political climate in a particular state and the new requirements for [...]
Series 65 Exam Opinions Requested
Seeking Opinions on How to Pass to the Series 65 Exam I am hoping readers of this blog would be able to provide some feedback on their experiences with the Series 65 exam. As a little background, many of our firm’s clients are managers who will be state registered investment [...]