Beginning on October 1, 2017, all investment advisers filing Form ADV must use an amended version of Part 1A of the Form that contains several new and revised items. Among other things, the amended Form requires expanded...more
Last week, the staff of the Securities and Exchange Commission (“SEC”) clarified its views on certain arrangements that can result in investment advisers having “custody” of client assets, as defined in rule 206(4)-2 (the...more
On February 12, 2015, the Securities and Exchange Commission (“SEC”) brought and settled charges against an investment adviser to several alternative mutual funds alleging, among other charges, failure to comply with the...more