In a letter to the NASAA today the SEC stated that they may extend the final deadline for IA registration under the Dodd-Frank Act. The reason for the extension is to give companies enough time to go through the registration process once final regulations are promulgated. The SEC stated that [...]
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San Francisco Hedge Fund Panel Event – April 5, 2011
Focus on Growing Your Hedge Fund in 2011 On Tuesday April 5 Linedata will be sponsoring a “Cocktails and Commentary” event at the Ritz Carlton in San Francisco. The event will begin at 3pm and will include the following panelists: Seth Blackman, Principal at Rothstein Kass Chris Grandi, President of [...]
Form ADV Part 2 Questions & Answers
SEC Provides Guidance on ADV Part 2 Many SEC and state registered investment advisers have completed the new Form ADV 2 as part of the annual updating amendment.* The SEC recently published guidance with respect to certain aspects of the new form. The question and answer style guidance deals with [...]
California Requests Input on IA Exemption Changes
Seeks to Raise IA Exemption Threshold to $100MM AUM In an Invitation for Comments released today, California officially seeks comments to change its rules with respect to hedge fund managers and a certain exemption from investment adviser registration. California currently exempts from registration those investment advisers with a place of [...]
Annual ADV Updating Amendment for IA Firms
Under SEC and state regulations, a registered investment advisory firm must file its annual amendment to Form ADV within 90 days of the end of its fiscal year. For most firms this means that the Annual Updating Amendment is due by March 31. In addition to the traditional updates which [...]
NASAA’s Proposed Model Rule to Exempt Private Fund Advisors from State Registration
One of the consequences of the Dodd-Frank Act is that federal and state jurisdiction over investment advisor firms will change. In general, fund managers with less than $150 million in AUM will not be subject to registration with the SEC.* While such managers will not be subject to SEC registration, [...]
SEC Study on Enhancing IA Examinations
Recommendations for Enhancing IA Exams Under Section 914 of the Dodd-Frank Act, the SEC was required to conduct a study with respect to the need for enhanced examination and enforcement resources for investment advisers. SEC staff recently released the study which is designed to provide Congress with recommendations with respect to [...]
New Form ADV Part 2 Update & Overview
Registered investment advisers (both SEC and state) will need to file their annual form ADV update within 90 days of the end of the fiscal year, which for most firms will be March 31, 2011. For many firms this will mean that they will also need to draft and submit [...]
2011 Final Renewal Statement for Registered Investment Advisers
As we noted previously, registered investment advisory firms and firm representatives must renew their registration annually by paying a fee to FINRA. In November FINRA issued a Preliminary Renewal Statement for each registered IA firm which stated the amount of renewal fees which were due by December 13, 2010. While [...]
Form ADV Requirements for Exempt Reporting Advisers
As we’ve discussed previously, the SEC has proposed two new exemptions from SEC registration for certain firms who would otherwise be required to register with the SEC as investment advisers: Section 203(l) (see Rule 203(l)-1) generally exempts investment advisers who only advise one or more “venture capital funds” and Section [...]