On December 1st and 2nd Private Equity International (PEI) will be hosting a Fund Compliance Forum in San Francisco. The forum will be focused on providing private equity firms with information on various Dodd-Frank compliance requirements, including the investment adviser registration requirement. Karl Cole-Frieman, a partner with Cole-Frieman & [...]
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Karl Cole-Frieman Speaking at Fund Compliance Event
Karl Cole-Frieman Speaking at San Francisco Hedge Fund Event
Dodd-Frank Implementation Considerations for Private Equity and Hedge Funds On October 18th Grant Thornton LLP and Financial Women’s Association of San Francisco will be hosting a panel discussion and reception focused on regulatory issues for hedge funds and private equity funds. Karl Cole-Frieman, a partner with Cole-Frieman & Mallon LLP, will [...]
Hedge Fund SEC Custody Rule Overview
Compliance Requirements of the SEC Custody Rule Hedge fund managers are preparing to register as investment advisers with the SEC pursuant to the new Dodd-Frank registration requirements. One of the issues which managers will be dealing with during that process is the hedge fund custody rule (Rule 206(4)-2 under the Investment [...]
States to Begin Proposing Rules on Expert Networks
Massachusetts Proposes Compliance Rules for Using Expert Networks Expert networks have been a major topic over the last few months and we are seeing the states, in addition to the SEC, focus on this area as a compliance issue for investment advisers. Massachusetts recently revoked the state investment adviser license [...]
Rule 204-4 – Reporting by Exempt Reporting Advisers
Proposed Rule 204-4 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 204-4 provides that certain “exempt reporting advisers” are required to file Form [...]
Rule 203A-5 – IA Registration Transition Rules
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 [...]
Rule 203A-1 – Switching to or from SEC IA Registration
Proposed Rule 203A-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 203A-1 will replace existing Rule 203A-1. The new rule will provide state [...]
SEC Proposes New IA and Hedge Fund Registration Rules
Seeks Public Comment on Proposed Regulations On November 19, the SEC released proposed rules with respect to the new hedge fund registration requirement under the Dodd-Frank act. The major proposals include the following: Rules with respect to the manner and process of registration of hedge fund and private equity fund [...]
SEC Rulemaking Agenda for Hedge Fund Registration
Timeline for Proposed & Final Manager Registration Rules Released The Dodd-Frank bill requires the SEC and CFTC to propose and promulgate final rules with respect to a number of important areas for investment managers. As we have seen, significant time has already been devoted to trying to develop a [...]
Form ADV Part 2 and State Registration
A couple of weeks ago the SEC announced that they approved certain updates for Form ADV Part 2 . While these forms will be required for managers who are subject to registration with the SEC (under the new rules, those managers with either $100 or $150 million of assets under [...]