Written by: Jay B. Gould On December 12, 2013, the Securities and Exchange Commission (SEC) charged a London-based hedge fund adviser and its former U.S.-based holding company with internal controls failures that led to the overvaluation of a fund’s assets and inflated fee revenue for the firms. The investigation came…
This article was published by Investcorp and is reprinted here with permission. Executive Summary This paper analyzes correlations between credit spreads and interest rates across various sectors and credit ratings in the US. Our work was prompted by chairman Bernanke’s announcement this summer of possible tapering of the ongoing quantitative easing program…
Written by: Jay B. Gould, Michael G. Wu and Jessica M. Brown In January, 2010, the Securities and Exchange Commission (“SEC”) announced its Enforcement Cooperation Initiative (“Initiative”), which provided the SEC with the ability to offer certain individuals or entities immunity or other preferential treatment in exchange for information about…
Written by: Jay B. Gould and Jessica M. Brown On October 28, 2013, the Securities and Exchange Commission (“SEC”) brought enforcement actions and imposed sanctions on three different registered advisers and their principals for violations of Rule 206(4)-2 under the Investment Advisers Act of 1940 (the “Custody Rule”). The circumstances…
This is a reminder that the 2014 IARD account renewal obligation for investment advisers starts this November. An investment adviser must ensure that its IARD account is adequately funded to cover payment of all applicable registration renewal fees and notice filing fees. Key Dates in the Renewal Process: November 11,…
Pillsbury was recently recognized for the second time as the “Best Onshore Law Firm – Hedge Fund Start-Ups” at the 2013 HFMWeek U.S. Hedge Fund Service Awards in New York City. This marks the fifth consecutive year Pillsbury has been honored by HFMWeek for its service to the hedge fund…
Written by: Jay B. Gould On October 23, 2013, the Securities and Exchange Commission (“SEC”) brought charges against three different investment advisory firms for recidivist behavior. The enforcement actions came out of the SEC’s Compliance Program Initiative, which targets firms that have been previously warned by SEC examiners about compliance…
Written by: Jay B. Gould On October 23, 2013, the Securities and Exchange Commission (“SEC”) voted unanimously to propose rules under the JOBS Act to permit companies to offer and sell securities through crowdfunding. Crowdfunding describes an evolving method of raising capital that has been used outside of the securities…
This article was published by Business in Canada and is reprinted here with permission. Business in Canada recently had the opportunity to interview Richard Taglianetti, a giant in the hedge fund universe who has raised millions of dollars for start-up managers over the course of his career. At present, Richard serves as the…
Written by: Michael G. Wu The National Futures Association (“NFA”) recently implemented a new quarterly reporting requirement for commodity trading advisors (“CTAs”). Under NFA Compliance Rule 2-46, CTAs must file on a quarterly basis NFA Form PR, which consists of the Commodity Futures Trading Commission’s Form CTA-PR together with additional…