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Increased SEC focus on broker-dealer registration issues for private fund managers

USA - April 12 2013 The Securities and Exchange Commission (SEC) is cracking down on private fund managers for not using registered broker-dealers for fundraising. At…

R. Scott Beach, Julia M. Boyd, Samuel A. Jennings, Greg H. Kahn

CFTC external business conduct standards - temporary relief to foreign exchange transactions

USA - May 8 2013 A no-action letter issued on May 2 provides swap dealers and major swap participants with temporary relief from compliance with External Business…

Eliza Sporn Fromberg

SEC Risk Alert Shines Spotlight on Private Funds

USA - September 25 2020 On June 23, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert focused on…

Eliza Sporn Fromberg, Erik A. Bergman, Peter J. Bilfield, Lydia Joo Lee

SEC issues amendments to investment adviser Custody Rule

USA - January 29 2010 The Custody Rule (Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (the "Advisers Act")), and certain recording-keeping requirements imposed under the Advisers Act, apply to federally-registered investment advisers that have (or are deemed to have) access to client assets.

R. Scott Beach, Jane Helen Broderick

"Custody Rule" information delays lead to enforcement against investment adviser

USA - November 4 2014 Securities and Exchange Commission (SEC) enforcement actions have moved out of the realm of punishing wrongdoers for harm caused and into preemptive…

Jennifer Genovesi Bassett