The U.S. Department of the Treasury requires U.S. issuers—including U.S.-resident investment funds—to report foreign residents’ holdings of U.S. securities every five years on its Treasury International Capital (TIC) Form...more
• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework.
• In response to certain frequently asked questions, the NFA has also updated its...more
1/15/2019
/ Best Practices ,
Books & Records ,
CFTC ,
Commodity Pool ,
Consumer Fraud ,
CPOs ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Employee Monitoring ,
Employee Training ,
Financial Services Industry ,
Guidance Update ,
Information Security ,
Information Systems Security Program (ISSP) ,
Internal Controls ,
Investment Management ,
NFA ,
Notification Requirements ,
Policies and Procedures ,
Popular ,
Recordkeeping Requirements ,
Risk Assessment
On December 20, 2018, the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (SEC) issued conditional no-action relief to Madison Capital Funding LLC (“Madison”), clarifying...more
Despite the new administration, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have both continued to make novel interpretations and to bring enforcement actions that break...more
10/11/2018
/ Acquisitions ,
Administrative Law Judge (ALJ) ,
Advertising ,
Anti-Money Laundering ,
Broker-Dealer ,
CFTC ,
Counter-Terrorist ,
Cryptocurrency ,
Enforcement Actions ,
EU ,
Fiduciary Duty ,
FinCEN ,
General Data Protection Regulation (GDPR) ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Mergers ,
NFA ,
Registered Investment Companies (RICs) ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
Introduction -
Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals....more
10/12/2017
/ Bad Actors ,
Bureau of Economic Analysis ,
CFTC ,
Cryptocurrency ,
Custody Rule ,
Cybersecurity ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Electronic Communications ,
Employee Retirement Income Security Act (ERISA) ,
EU ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Direct Investment ,
Form ADV ,
Fund Expenses ,
GAAP ,
General Data Protection Regulation (GDPR) ,
Hedge Funds ,
Insider Trading ,
Investment Adviser ,
Investment Management ,
IRS ,
MiFID II ,
NFA ,
Pay-To-Play ,
Private Equity Funds ,
Private Funds ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Tax Audits
Key Points -
- The supplemental proposed rulemaking to Regulation AT heightens the procedural mechanisms by which source code is made accessible to the CFTC.
- The supplemental proposed rulemaking adds a...more