the same restrictions on communications with the public to which they are currently subject.ย Form D The current Form D filing document will be amended to include a โcheck-the-boxโ option…
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Admit It! SEC May Seek Admissions of Wrongdoing in Settlements
still forthcoming on the scope of the proposed changes to the SEC policy, which will require approval from a majority of the five SEC commissioners. However, Chairman White presumably would…
Performance Fantasies Lead to SEC Enforcement Action
was hired in 2003 as an assistant analyst to track performance and create personalized pitchbooks for use by Stanford financial advisers in one-on-one presentations with prospective clients.ย DโAmato calculated the…
The SEC Proposes Rules To Reform The Way Money Market Funds Operate
material events and sponsor support; (ii) eliminate the 60-day delay on public access to the information filed on Form N-MFP regarding portfolio holdings; (iii) amend Form PF to improve private…
Best Laid Plans Gone Awry: Practices for Rule 10b5-1 Trading Plans
Rule 10b5-1 trading plans. Rule 10b5-1 trading plans are no stranger to controversy. First introduced in 2000 by the Securities and Exchange Commission (SEC), Rule 10b5-1 trading plans permit a…
Private Equity Fund Managers as Unregistered Broker Dealers โ Sanctions and Rescission
uncommon for a fund manager to direct the payment of fees by a portfolio company of the fund to one of its affiliates in connection with the acquisition, disposition (including…
JOBS Act Implementation Update
implementation of the JOBS Act. Regarding the implementation of the lift on the prohibition against general solicitation, the SEC said its staff are โdeveloping recommendations for the Commissionโs consideration as…
SEC puts Hedge Fund Managers on Notice regarding Compensation Arrangements for Sales
ย This post will address only the sales compensation activities of hedge funds with an explanation of the private equity investment banking fee discussion to follow. Mr. Blass indicated that he…
A Conversation with the Regulators: A program for Fund Managers and Investment Advisors
REGISTER NOW! Pillsbury and the California Hedge Fund Association invite you to join us on Thursday, April 25, 2013 for an educational program featuring Ms. Jan Lynn Owen, the…
SEC Hammers Private Equity Fund Manager
press release, the SEC reiterated its focus on the valuation process, the use of valuations to calculate fees and communicating such valuations to investors and to potential investors for purposes…