September 22, 2011

 

Reminder: Certain Amendments to Form ADV Part 1A Regarding the Calculation of Assets Under Management ("AUM") and Required Disclosure of Information Regarding Private Funds will be programmed into the IARD System by December 31, 2011

 

In Adopting Release 3221 (June 22, 2011), the Securities and Exchange Commission (the "SEC") adopted certain amendments to Form ADV Part 1A. Most notably, the revisions require additional information regarding an investment adviser’s private fund clients to be disclosed in Section 7.B. of Schedule D of Form ADV ("Section 7B") and alter the manner by which registered investment advisers must calculate their AUM.

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September 22, 2011

 

SEC Request for Comment on Retrospective Review of Existing Regulation

On July 11, 2011, President Obama issued Executive Order 13579, "Regulation and Independent Regulatory Agencies," which states that regulatory agencies of the federal government should promote the goal of a regulatory system that protects "public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation." In furtherance of its ongoing efforts to update regulations to reflect market developments and changes in the regulatory landscape, and in light of Executive Order 13579, on September 6, 2011, the Securities and Exchange Commission (the "SEC") invited the public to submit comments to assist the SEC in considering the development of a plan for the retrospective review of its regulations.

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July 21, 2011

 

Treasury Announces Approval Of and Intitial Reporting Date for TIC & Form SLT

The U.S. Department of the Treasury recently announced that the Office of Management and Budget has approved additional reporting requirements to be made on Treasury International Capital Form SLT (“Form SLT”). These requirements will become effective with the report which lists holdings as of September 30, 2011 instead of as of June 30, 2010 as originally proposed. Reporters will be required to file a subsequent report of holdings as of December 31, 2011 with mandatory monthly reporting on Form SLT required beginning with the report which lists holdings as of January 31, 2012.

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