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Written by: Jay B. Gould and Peter Chess On April 18, 2012, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) voted to adopt rules…

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exemption under CFTC Rule 4.13(a)(3).  Rule 4.13(a)(4) previously exempted private pools from registering as a CPO with the CFTC for funds offered only to institutional qualified eligible purchasers (“QEPs”) and…

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a summary of the primary annual or periodic compliance-related obligations that may apply to Investment Advisers.  The summary section begins with what we feel are “hot” areas of compliance for…

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it easier for smaller companies to raise capital and would lessen the regulatory burden on those companies.   Legislators have introduced eight different proposals in Congress to make it easier…

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such as money market funds registered with the SEC may be required to report on the Form, in addition to “private funds.” 2.  Do investment advisers need to file the…

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“2012 Letter”) in response to a request for guidance from the American Bar Association’s Subcommittee on Hedge Funds on issues regarding the registration of certain investment advisers that are related…

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an “evergreen” brochure that just addresses investment process. This evergreen document should retell in print what you communicate verbally at a pitch meeting for educating and persuading people to understand…

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that provides advice only to qualifying private funds, which include 3(c)(1) and 3(c)(7) funds.  A grandfathering provision for private advisers is also included.  The Massachusetts Securities Division released amendments similar…