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Mark Your Calendars: Key Compliance Dates for Advisers thumbnail

Mark Your Calendars: Key Compliance Dates for Advisers

It’s hard to believe that January is almost over and 2013 just a blur.   With matching speed, many of the compliance milestones that an investment adviser faces...

Setting the Stage for 2014: SEC Announces Exam Priorities thumbnail

Setting the Stage for 2014: SEC Announces Exam Priorities

Pay attention to this one.  Earlier this month, the SEC Office of Compliance Inspection and Examination issued its annual list of 2014 examination priorities for a variety...

SEC Proposes Regulation A+ For Small Businesses thumbnail

SEC Proposes Regulation A+ For Small Businesses

With all eyes focused on the lifting on the ban on solicitation and the new proposed equity crowd funding rules, one major rulemaking proposal mandated under the...

Year in Review: SEC Round Up for 2013 thumbnail

Year in Review: SEC Round Up for 2013

I love taking stock of the highlights of a year as it draws to a close, so I am doing a mini-series of posts on topic.  The...

Open for Comment: FINRA’s Funding Portal Rules thumbnail

Open for Comment: FINRA’s Funding Portal Rules

With all the noise about the proposed set of rules for crowdfunding the SEC released in October, one piece of the puzzle almost slipped by unnoticed. In...

The Annual Drill—Calculating Regulatory Assets Under Management for Form ADV thumbnail

The Annual Drill—Calculating Regulatory Assets Under Management for Form ADV

While working on the chapter on Regulatory Assets Under Management for my new book about Dodd Frank and the Advisers Act, I realized that now would be...

SEC Issues Guidance on General Solicitation Rules thumbnail

SEC Issues Guidance on General Solicitation Rules

On November 13, the SEC released Compliance and Disclosure Interpretations (“C&DIs”) for the new rules authorizing general solicitation and advertising for securities offerings relying on Rule 506(c)...

SAC Capital, Insider Trading and the Southern District thumbnail

SAC Capital, Insider Trading and the Southern District

It would be old news already if the case had not garnered so many superlatives.  One of the country’s most famous hedge fund managers.  The largest insider...

FINRA Cracking Down on “No Fee” Advertising thumbnail

FINRA Cracking Down on “No Fee” Advertising

FINRA recently expressed concerns about broker-dealers who advertise “free” or “no fee” services for retail brokerage accounts and individual retirement accounts (IRAs). FINRA Rule 2210 requires that...

SEC Examinations Targeting Advisers Who Are Still Waiting for Godot thumbnail

SEC Examinations Targeting Advisers Who Are Still Waiting for Godot

I have worked with a number of advisers who have never ever been examined by the SEC, not once in their 10 +, 15+, etc. years of...

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