Blog Posts - Investment Adviser



Summary of the Proposed Amendments to Form ADV and Investment Advisers Act Rules

On May 20, 2015, the SEC issued proposed amendments to Form ADV and the Investment Advisers Act rules. In the release, the SEC proposed amendments to Form ADV that would require advisers to disclose additional information, such as information about s...
by Strictly Business on Jul 31, 2015

SEC Enforcement Division’s Asset Management Unit’s Chief Anticipates Increase in Private Equity Enforcement

Bruce Karpati, the Chief of the SEC Enforcement Division’s Asset Management Unit, held a Q&A session entitled “Private Equity Enforcement Concerns” at the Private Equity International Conference held in New York on January 23, 2013. He addr...
by Strictly Business on Feb 14, 2013

SEC Enforcement Division’s Asset Management Unit Chief Reveals New Priorities in Regulation of Private Funds

Bruce Karpati, Chief of the SEC Enforcement Division’s Asset Management Unit, gave a speech entitled “Enforcement Priorities in the Alternative Space” on December 18, 2012. The recently established 75-member Asset Management Unit (AMU) is dedic...
by Strictly Business on Jan 9, 2013

Unlikely Coalition Comes Together in Opposition to the Creation of an SRO for Investment Advisers

As part of the Dodd-Frank Act, Congress directed the SEC to review whether a so-called “self-regulatory organization” (or “SRO”) should be created to regulate investment advisers. Doing so would make investment adviser regulation more akin to...
by Strictly Business on Aug 6, 2012

Maryland Securities Commissioner Issues New Order Adopting a Private Fund Exemption Based on Model NASAA Rule

On June 15, 2012, the Maryland Securities Commissioner issued an order adopting the NASAA model rule exemption for investment advisers to private funds. Like the model rule, the new order issued by the Maryland Securities Commissioner, provides for a...
by Strictly Business on Jun 22, 2012

Missouri Commissioner of Securities Proposes New Private Fund Exemption Based on Model NASAA Rule

On April 26, 2012, the Missouri Commissioner of Securities proposed revised regulations exempting certain private fund managers from investment adviser registration with the State of Missouri. Background Prior to the repeal of the federal 15-client e...
by Strictly Business on May 9, 2012

Massachusetts Securities Division Adopts Final Private Fund Adviser Exemption Based Upon NASAA Model Rule

Previously, I reported that the Massachusetts Securities Division had proposed an exemption from investment adviser registration for advisers to private funds.  In late winter, the division adopted these regulations as final (with small changes).  ...
by Strictly Business on Apr 19, 2012

The SEC Increases the Net Worth Requirement of the Definition of “Qualified Client” Impacting Both Registered and Some Unregistered Private Fund Managers

Private fund managers who are registered with the SEC are required to follow federal regulations on performance compensation.  Generally, if a registered fund manager desires to collect fees based on fund performance (such at the typical 20% carried...
by Strictly Business on Feb 23, 2012

Virginia Division of Securities Proposes New Private Fund Exemption Based on Model NASAA Rule

On February 14, 2012, the Virginia Division of Securities and Retail Franchising proposed revised regulations exempting certain private fund managers from investment adviser registration with the Commonwealth of Virginia. Background Prior to the repe...
by Strictly Business on Feb 18, 2012

California Department of Corporations Proposes New Private Fund Exemption

On December 15, 2012, the California Department of Corporations proposed revised regulations exempting certain private fund managers from investment adviser registration with the state of California. Background Previously, under Cal. Code Regs. tit.
by Strictly Business on Feb 9, 2012


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