The SEC’ Division of Investment Management issued new guidance to reminds firms to comply with conditions and representations in exemptive orders. The guidance suggests that firms “adopt and implement policies and procedures reasonably designed to ensure ongoing compliance with each representation and condition in any such order.” The guidance was triggered by June 2011 report [...]
About Doug Cornelius
SEC’s Compliance Outreach Program
I was able to attend the Boston stop on the SEC’s Compliance Outreach Program. Michael Garrity, the Associate Director of the Boston Examination Program kicked off the program, by highlighting some examination statistics. There are 1200 registered adviser in the Boston region. But there are only 50 examiners. Last year, they had 80 exams. They [...]
Compliance Bricks and Mortar for May 17
These are some of the compliance-related stories that recently caught my attention. White: SEC’s No. 1 priority is more adviser examinations By Mark Schoeff Jr. in Investment News The Securities and Exchange Commission’s top priority is to increase the number of investment adviser examinations it handles every year. How to go about doing that is [...]
Placement Agents and the SEC Inquiry of Private Fund Broker Dealer Requirements
Broker-dealer regulation in connection with the sale of private fund interests has become a focus of SEC inquiry. The David Blass speech on private funds and broker-dealer registration highlights the issue. If you have internal marketing people who are getting paid transaction based compensation for selling fund interests, there may be an issue. Even if you don’t [...]
AIFMD in the UK
HM Treasury has published its response to its first consultation on the transposition of the Alternative Investment Fund Managers Directive (“AIFMD”) in the United Kingdom. The main thrust of the AIFMD will not hit Europe for a few years, but in the meantime there will be more uniform limitations on private placements in the European Union [...]
Compliance Bricks and Mortar for May 10
These are some of the compliance-related stories that recently caught my attention. AIFMD Update – US Private Fund Advisers Marketing in the UK in Compliance Avenue Recent news from the UK suggests that these AIFMs have most likely been granted a reprieve until July 22, 2014 to comply with AIFMD in the UK. Earlier this [...]
FINRA Issues Regulatory Notice on Communications Regarding Real Estate Investments
FINRA issued Regulatory Notice 13-18 on compliance with the communications with the public rule concerning communications about unlisted REITS and other real estate investments. Among other things, FINRA is concerned about the use of pictures of real property in the marketing materials. FINRA Rule 2210 regulates broker-dealer communications with the public. Clearly, based on the [...]
Private Equity Real Estate 50: Which are Registered with the SEC?
Private Equity Real Estate just released its ranking of the top 50 real estate private equity fund managers. As I have done in the past, I parsed the list to see which managers are registered with the Securities and Exchange Commission as investment advisers. (Disclosure: my company is on the list.) 1 The Blackstone Group [...]
Compliance Bricks and Mortar for May 3
These are some of the compliance-related stories that recently caught my attention. SAC to Begin Clawing Back Compensation in Insider Trading Cases by Peter Lattman in DealBook On Thursday, Mr. Cohen sought to convince SAC investors and regulators that he takes compliance seriously. In a letter to his investors, Mr. Cohen announced a broad set [...]
Day Two at PEI’s Private Fund Compliance Forum
These are my notes from the Thursday sessions at PEI Media’s Private Fund Compliance Forum 2013. The Day started out with a closed door session called the CCO Think Tank. Since the doors were closed, I’m not going to share any specific notes. The public sessions: What’s on the regulatory horizon and how will it [...]
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