Broker Dealer | Examinations and Audits | FINRA | FINRA Rules
Broker-Dealer To-Do List to Comply with FINRA Changes to Registration Rules
FINRA has implemented several new registration and designation requirements that member firms will need to address on October 1. See FINRA Regulatory Notice 17-30. The To-do List includes the following,…
Anti-Money Laundering | CIMA | Offshore Funds | Private Investment Funds
Cayman Islands Fund Managers Face New Anti-Money Laundering Requirements
The Cayman Islands Monetary Authority (“CIMA”) made a number of key changes to its anti-money laundering (“AML”) regulations in 2018 (the “AML Regulations”) including expanding their reach to unregulated entities,…
Anti-Money Laundering | Beneficial Ownership | CIMA | Offshore Funds | Private Investment Funds | Regulatory Filings
Cayman Islands Requires Companies to Maintain Beneficial Ownership Register; Is Your Fund In or Out (of Scope)?
As of July 1, 2018, companies and limited liability companies incorporated or registered in the Cayman Islands are required to maintain a beneficial ownership register at their Cayman Islands-registered offices…
Broker Dealer | Disclosures | DOL | DOL Fiduciary Rule | ERISA | Investment Advisers Act
The Fiduciary Rule is Dead — What Should Investment Advisers and Broker-Dealers Do Now?
The headlines have been heralding the demise of the Department of Labor’s (DOL) Fiduciary Rule. But what does it really mean? Let’s look at what happened. On March 15, 2018,…
Best Execution | Conflicts of Interest | Mutual Funds
Why the SEC is Obsessed with Mutual Fund Share Class Selection and Disclosure (and why you should be too)
On April 6, 2018, the SEC released three settlement orders with investment advisers because they “failed to disclose conflicts of interest and violated their duty to seek best execution by…
Best Execution | Conflicts of Interest | Disclosures | Mutual Funds | SEC News
SEC Offers “Favorable Terms” to Advisers that Self-Report Failure to Disclose Receipt of 12b-1 Fees
On February 12, 2018, the SEC Division of Enforcement announced a new self-reporting initiative – the Share Class Selection Disclosure (the “SCSD Initiative”). The Initiative, led by the Commission’s Asset…
Form ADV | Investment Advisers Act | Regulatory Filings
Feeling your Pain: Advice on Answering Form ADV’s Trickier Questions
Working through the Form ADV update has been especially challenging this year for many investment advisers. Aside from the traditionally confusing questions, the Form has been updated to include some…
Investment Company Act | Liquidity | Mutual Funds
SEC Requires Mutual Funds to Adopt Liquidity Risk Management Programs
The SEC adopted new mutual fund liquidity Rule 22e-4 (the “Rule”) under the Investment Company Act of 1940 on October 13, 2016, in a decision that has been considered by…
Blue Sky Filings | Hardin News | Hedge Funds | Private Equity Funds | Private Investment Funds | Private Placements | Regulatory Filings
Hardin Compliance Now Offers Blue Sky Filings Services for Hedge and Private Fund Managers
Complying with Blue Sky Laws can be complicated and burdensome, and engaging outside counsel to perform the filings can be expensive. At Hardin, we have the consultants and tools necessary…
Form ADV | Investment Advisers Act | Regulatory Filings
Form ADV Updates Due March 31, 2018
IARD will be open on Saturday, March 31, 2018, therefore the deadline for filing an annual updating amendment to Form ADV will NOT be extended to Monday, April 2, 2018. …