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NFA Excludes Certain Remote Work Arrangements From Its Branch Office Definition

USA - October 7 2021 On September 23, 2021, National Futures Association (“NFA”) rule amendments became effective that will permit NFA-member managers to authorize certain…

Marc E. Elovitz, Heather N. Wyckoff

Reminder: NFA Member Managers and Virtual Currency Disclosures

USA - August 4 2021 As an increasing number of investment managers are exploring virtual currency spot and derivative trading as part of their investment programs…

Marc E. Elovitz, Heather N. Wyckoff

Qualified Client “Assets-Under-Management” and “Net Worth” Test Amounts Increased to $1.1 and $2.2 Million, Respectively

USA - July 1 2021 Section 205(a)(1) of the Investment Advisers Act of 1940, as amended (“Advisers Act”), generally prohibits registered investment advisers (“RIAs”)…

Patrick Dundas

CFTC Adopts New Position Limits Rules The impact on private fund managers

USA - January 27 2021 On Oct. 15, 2020, the Commodity Futures Trading Commission ("CFTC") adopted a "Final Rule" on a new position limits regime that covers 25 physical…

Brian T. Daly

White House Bans Trading in 31 Chinese Companies

China, USA - November 13 2020 On Nov. 12, 2020, President Donald Trump signed an Executive Order1 that, effective Jan. 11, 2021, will impose a ban on trading by U.S. persons in the…

Brian T. Daly, Gregory L. Kinzelman, Betty Santangelo, Gary Stein, Hannah Thibideau