SEC issues additional guidance regarding the custody rule after finding wide spread and varied non-compliance by investment advisers *

USA - March 11 2013
Last week the SEC issued a Risk Alert and an Investor Bulletin on the Custody Rule after its National Examination Program ("NEP") observed…

Co-authors: Jay B. Gould.

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SEC examinations target private equity and hedge fund managers for 2013 *

USA - February 25 2013
On February 21, 2013, the Staff of the Securities and Exchange Commission (the "Staff" and the "SEC," respectively) published its 2013 priorities for…

Co-authors: Jay B. Gould.

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Registered investment advisers: annual compliance obligations--what you need to know *

USA - February 7 2013
As the new year is upon us, there are some important annual compliance obligations Investment Advisers either registered with the Securities and…

Co-authors: André W. Brewster , Jay B. Gould, Ildiko Duckor.

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Private funds and the JOBS Act *

USA - May 8 2012
The Jumpstart Our Business Startups Act (the “JOBS Act” or the “Act”), signed into law by President Obama on April 5, 2012, seeks to encourage economic growth through the easing of certain restrictions on capital formation and by improving access to capital. 

Co-authors: Peter J. Chess, Jay B. Gould.

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CFTC eliminates key CPO registration exemption - what does this mean for fund of funds? *

USA - March 14 2012
The Commodity Futures Trading Commission (the “CFTC”) recently amended its registration rules regarding Commodity Pool Operators (“CPOs”) and Commodity Trading Advisors (“CTAs”), which will require many general partners and managers of private investment funds that previously relied on an exemption from registration to now register with the CFTC. 

Co-authors: Peter J. Chess, Jay B. Gould.

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