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to purchases and sales separately, and must be reported on separate schedules to the BE-180. Consequently, a U.S. reporter, for example, that only exceeds the threshold for sales but does…

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Pillsbury Winthrop Shaw Pittman LLP is pleased to present an exclusive client discount for the upcoming: ย Hedge Fund General Counsel and Compliance Officer Summit October 19, starting…

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The U.S. Treasury Departmentโ€™s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015 which, among other things, would add SEC-registered investment advisers to…

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be delegated authority by FinCEN to examine investment advisers for compliance. The proposed rule also makes investment advisers fall under the definition of โ€œfinancial institution,โ€ requiring them to file Currency…

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regulators should permit asset managers to settle cases without admitting culpability. In response to that question, Ms. Mann, who has expertise in investment advisor regulatory and fund-related matters, commented โ€œIf…

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(4) provide ongoing training for appropriate persons who are involved with the program. The new rules are likely to reflect comments received in response to the 2003 proposal and may…

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a view towards shifting income to their foreign affiliates. READ MOREโ€ฆ Read this article and additional publications at pillsburylaw.com/publications-and-presentations.ย  You can also download a copy of the Client Alert. Print…

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to the Exchange Act requiring the SEC to adopt rules to provide for the registration of SBS dealers and major participants. Once registered, SBS dealers and major participants will be…

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for services. These proposed regulations are aimed at attempts by investment fund managers to convert ordinary, management fee income into tax-favored long-term capital gains through the use of management fee

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funds, institutional separate accounts and sub-advised mutual funds. ย Kristin Snyder, Associate Regional Director for Examinations, San Francisco Regional Office of the Securities and Exchange Commission, emphasized that while the SEC…