Comments on: Counting Clients under the Investment Advisers Act – The Demise of the Hedge Fund Rule

By: Fund Manager Fraud for Exceeding Lerverage Limits | Compliance Building

Fund Manager Fraud for Exceeding Lerverage Limits | Compliance Building — Tue, 27 Jul 2010 12:02:14 +0000

[...] legal team used the Goldstein v. SEC case to argue that the SEC is precluded form treating fund investors as clients. The Sixth Circuit Court [...]

By: Private Equity and the Custody Rule | Compliance Building

Private Equity and the Custody Rule | Compliance Building — Tue, 08 Jun 2010 12:02:05 +0000

[...] the impending removal of the 15 Client Rule exemption from registration with the SEC, I was scratching my head trying to figure how to make the [...]

By: More on the Private Fund Transparency Act of 2009 | Compliance Building

More on the Private Fund Transparency Act of 2009 | Compliance Building — Fri, 19 Jun 2009 12:40:22 +0000

[...] I am not sure what this change would do. I suspect it is an attempt to address the demise of the Hedge Fund Rule and allow the SEC to define the investors in private investment funds as “clients” of [...]

By: Compliance Building · Counting Clients under the Investment Advisers Act

Compliance Building · Counting Clients under the Investment Advisers Act — Wed, 25 Mar 2009 15:55:46 +0000

[...] to feed ‹ Counting Clients under the Investment Advisers Act – The Demise of the Hedge Fund Rule • SAFETY Act [...]

By: Compliance Building · Anti-Fraud Provision of the Investment Advisers Act

Compliance Building · Anti-Fraud Provision of the Investment Advisers Act — Wed, 25 Mar 2009 15:44:11 +0000

[...] Although negligent conduct is proscribed, the SEC specifically stated that the rule does not create a fiduciary duty not otherwise imposed by law. This rule should not change the way an investment advisers perform their duties. It merely removes the doubt regarding the scope of the SEC’s authority created by Goldstein. [...]