Rule 13h-1 Adopted by SEC Today the SEC adopted new Rule 13h-1 which requires certain large traders to provide certain information regarding their trading activities to the SEC through a New Form 13H.  A gross overview of the new reporting requirement are provided below. Who is required to file Form [...]

SEC Releases Information on Mid-Sized Advisers – New York Managers may be Required to Register with SEC Currently managers with a place of business in New York are not required to register as investment advisers at the state level with the New York Department of State.  Until the Dodd-Frank Act [...]

Bill Would Have Significant Impact on Private Funds On July 12, 2011, United States Senator Carl Levin (D – Michigan) introduced the Stop Tax Haven Abuse Act of 2011 (the “Bill”). A prior version of the Bill was introduced in 2009. The Bill contains several provisions of interest to private [...]

Proposed Form PF Released For your review, we have published the proposed Form PF which can be found here: Form PF. According to an SEC proposal announcement last week, SEC registered managers will be required to file proposed Form PF with the SEC on either a quarterly or annual basis [...]

Recommendation for Uniform Fiduciary Duty Under Section 913 of the Dodd-Frank Act, the SEC was required to condict a study of the effectiveness of the current legal and regulatory structure for broker-dealer firms and investment advisory firms with respect to the provision of personalized investment advice to retail customers and [...]

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 [...]

SEC Proposed Rule 203(m)-1 under Investment Advisers Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act. New Advisers Act Section 203(m)-1 provides an exemption from registration with the SEC to those groups [...]

SEC Proposed Rule 203(l)-1 under Investment Advisers Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act. New Advisers Act Section 203(l) provides an exemption from registration with the SEC to those groups [...]

Proposed Rule 202(a)(30)-1 Pursuant to Dodd-Frank Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act.  The following proposed new rule 202(a)(30), among other things, defines the terms “client” and “investor” for the [...]

Proposed Rule 203A-5 Pursuant to Dodd-Frank Act The SEC has proposed certain new rules as well as amendments to existing rules under the Investment Advisers Act as a result of the Dodd-Frank Act.  The following proposed new rule 203A-5 provides that (i) SEC registered investment advisers must report their AUM [...]