A MANAGERS-ONLY EVENT RSVP NOW ! Thursday, October 27, 2011 3:30 – 4:00pm Registration 4:00 – 5:30pm Presentation 5:30 – 6:30pm Reception Pillsbury’s San Francisco office 50 Fremont Street San Francisco, CA 94105 How can hedge fund managers that seek more efficient methods for raising capital avail themselves of…
Written by Jay B. Gould and Michael Wu On October 9, 2011 Governor Brown signed into law Senate Bill 398 which is intended to clarify the current law regarding placement agents and lobbyist requirements. In 2009, AB 1584 was enacted. AB 1584 imposed disclosure requirements for investment placement agents associated…
Written by Jay Gould Pillsbury’s Investment Funds & Investment Management team has submitted a comment letter to the California Department of Corporations (the “DOC”) on behalf of the California Hedge Fund Association in connection with the DOC’s recently proposed amendments to the California custody rule. In its letter to the Commissioner, Pillsbury requested that the…
Written by Jay Gould and Michael Wu On March 2, 2011, Pillsbury’s Investment Fund and Investment Management group (“Pillsbury IFIM Group”) submitted a comment letter to the North American Securities Administrator’s Association (the “NASAA”) on behalf of the California Hedge Fund Association and the Florida Alternative Investment Association. The letter…
Written by Michael Wu California’s Department of Corporations (the “Department”) intends to issue emergency regulations to address the elimination of the “private adviser exemption” under Section 203(b)(3) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Currently, an investment adviser in California may rely on the private adviser exemption…
Written by Michael Wu In early March, Pillsbury submitted a comment letter to the North American Securities Administrators Association (NASAA) on behalf of the private fund industry regarding NASAA’s proposed model custody rule. Please see here for more information. NASAA has recently confirmed that it has changed a key component…
Written by Jay Gould and Michael Wu Pillsbury’s Investment Fund and Investment Management group recently submitted a comment letter to the North American Securities Administrator’s Association (the “NASAA”) on behalf of the private investment fund industry. Specifically, the letter to the NASAA was intended to provide comments regarding the proposed…
On September 30, 2010, California Governor Arnold Schwarzenegger signed into law AB 1743, which regulates the activities of placement agents who solicit investments from public pensions on behalf of investment managers. The new law: prohibits a person from acting as a placement agent in connection with any potential investment by…
As we have previously discussed here, the Securities and Exchange Commission adopted significant changes to Part 2 of Form ADV. Among other things, the new Part 2 requires greatly expanded disclosure presented in a narrative, plain English format. The California Department of Corporations has now also adopted the new Part 2, effective…