SEC Releases New Rule on Family Offices for IA Registration Exclusion The Dodd-Frank Act created a new “family office” exclusion from the definition of investment adviser because the private advisor exemption was repealed.  While Congress believed that family offices should not be subject to the SEC registration requirements, it did [...]

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 [...]

If your firm is registered as an investment adviser (IA) then you have probably received notice to renew your firm’s registration for 2011.  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 and IA representatives [...]

In Section 409 of Dodd-Frank Act, Congress required the SEC to define “family office” for the purpose of exempting such groups from the registration requirements under the Advisers Act.  Section 409 provides that any definition the SEC adopts should be “consistent with the previous exemptive policy” of the SEC and [...]

At the end of July, the SEC adopted amendments to Form ADV Part 2 and the related rules.  The amended Form ADV Part 2 will be used by SEC-registered advisers to meet their disclosure obligations and generally describe the adviser’s services, fees, and strategies. On September 1, 2010, the California [...]

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 [...]

New Form to Require More Disclosure On July 21, the SEC approved changes to the Form ADV Part II which are designed to provide more and better information to investors.  Currently Part II (and Schedule F which qualifies much of the information on Part II) contains a series of check [...]

As has been widely reported, the Senate passed the Financial Reform Bill setting the stage for President Obama to sign the bill within the next week.  With respect to investment advisors, one of the central items is the private equity and hedge fund registration requirement.  We will be reporting further [...]

After the passage of the Dodd-Frank financial reform bill, managers and service providers will be preparing to go through the registration process. Managers should note that while the registration process is fairly straightforward, the ongoing compliance requirements under the Investment Advisers Act are perhaps more important. In this guide we [...]

IAPD Update Provides Information on IA Reps The Investment Adviser Public Disclosure (IAPD) was updated this week so that information on investment adviser representatives will now be available online.  Previously the search function allowed members of the public to access information on IA firms only.  The previous information available through the [...]