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SEC Examinations Target Private Equity and Hedge Fund Managers for 2013

On February 21, 2013, the Staff of the Securities and Exchange Commission (the “Staff” and the “SEC,” respectively) published its 2013 priorities for the National Examination Program (“NEP”) in order to provide registrants with the opportunity to bring their organizations into compliance with the areas that are perceived by the…

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Jay Gould on Starting a Hedge Fund in 2013

  Pillsbury partner Jay Gould talks about Challenges and Opportunities for Starting a Hedge Fund in 2013, a program co-sponsored by the law firm, and why he thinks 2013 will indeed be a good year for hedge fund managers. Learn more: https://www.pillsburylaw.com/investment-funds-and-investment-management

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ANNUAL COMPLIANCE OBLIGATIONS–WHAT YOU NEED TO KNOW, February 6, 2013

As the new year is upon us, there are some important annual compliance obligations Investment Advisers either registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Adviser”) should be aware of. See upcoming deadlines below and in red throughout this document. The following is…

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Jay Gould quoted on investor accreditation practices associated with the JOBS Act

San Francisco Corporate & Securities partner Jay Gould is quoted in Compliance Week on new investor accreditation practices associated with the JOBS Act. JOBS Act Puts Spotlight on Investor Accreditation Practices Compliance Week January 23, 2013 When the Jumpstart Our Business Startups Act, known as the JOBS Act, was enacted…

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Pillsbury to Host Managers Only Program

Pillsbury will be hosting a Managers Only program on Wednesday, January 23, 2013.  The program entitled “Challenges and Opportunities for Starting a Hedge Fund in 2013” starts at 3:30 p.m. and will be held at Pillsbury’s San Francisco office at Four Embarcadero Center, 22nd Floor.  This event will be divided…

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Hold Your JOBS Act Horses

Written by:  Jay Gould When can private fund managers start posting performance numbers on their websites and sponsoring the Super Bowl?  Not yet, according to Senator Carl Levin (D-MI) in letters dated October 5,2012 and October 12, 2012, (the “Levin Letters”) rebuking the SEC for having missed the point of…

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NASAA President Criticizes New SEC Rule Allowing General Advertising

Written by:  Jay Gould and Peter Chess Heath Abshure, President of the North American Securities Administrators Association (NASAA) and Arkansas State Securities Commissioner, sharply criticized the Securities and Exchange Commission’s (the SEC’s) new rulemaking that will lift restrictions on general solicitation and general advertising for hedge funds and other private…

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Third Party Marketers Must File PPMs with FINRA

Written by: Jay Gould and Peter Chess Effective December 3, 2012, hedge funds and other private funds that rely on Section 3(c)(1) of the Investment Company Act (“3(c)(1) Funds”) and which sell their interests through third party marketers, must ensure that their private placement memoranda (“PPM”) are filed with FINRA,…

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Excellence In Investing: San Francisco

The 3rd Annual Excellence In Investing: San Francisco, in partnership with The Sohn Conference Foundation, will be held on October 24, 2012 at the Merchants Exchange, Julia Morgan Ballroom.   Excellence In Investing: San Francisco is the premiere Bay Area investor conference benefiting local and national education and other children’s causes.…