Nominations are open for the 2010 Clawbies, , honoring the best in Canadian legal blogs. My old blog, KM Space, was a past two-time winner of a Clawbie: Friend of the North 2007 and Friend of the North 2008. Compliance Building stayed on the Clawbie list for 2009. It looks like I didn’t pay much [...]
Archive | December, 2010
Which Real Estate Fund Managers are Registered with the SEC?
After looking at whether a fund manager is an investment adviser and whether real estate is a security, I looked at the Private Equity Real Estate News list of the 30 biggest private equity real estate firms in the world (.pdf). (Disclosure: my company is on the list.) How many of them are already registered [...]
Compliance Bits and Pieces for December 3
Here are some recent compliance-related stories that caught my attention: Transparency International Alleges Intimidation in Pakistan by Joe Palazzolo in WSJ.com’s Corruption Currents Transparency International says its branch in Pakistan has received death threats from government officials, in connection with the anti-corruption organization’s agreement with the U.S. to monitor aid flows to the country. Syed [...]
Job Description For CCOs of Advisers to Private Investment Funds
Back in 2005, Associate Director Office of Compliance Inspection and Examinations of the SEC, Gene Gohlke gave a speech addressing hedge funds who would soon have to register under the doomed hedge fund rule. He focused on what the funds needed in a Chief Compliance Officer. Rule 206(4)-7 requires a registered investment adviser to designate [...]
Calculating Regulatory Assets Under Management for Private Funds
For private fund managers, one troubling aspect of Form ADV had been the calculation of “assets under management” in item 5.F. If securities are less than 50% of the portfolio then the portfolio would not be a securities account. Except for real estate debt funds, most real estate funds would end up with $0. (I’m [...]
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