SEC Compliance Program Annual Reviews: A Guide for Newly Registered Advisers

A&O Shearman
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The Securities and Exchange Commission estimates that approximately 1,300 hedge and private equity fund managers registered as investment advisers with the agency as a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act’s rule changes. Many of those firms registered just ahead of the March 31, 2012 registration deadline and recently ‘‘celebrated’’ their one-year anniversary operating as SEC-registered investment advisers.

Anniversaries prompt reflection on where one has been and what lies ahead, and, indeed, SEC compliance program rules direct investment adviser compliance officers to do just that. The rules require an annual review of an asset management firm’s compliance program and specify two goals for that review...

Originally published in Securities Regulation & Law Report, 45 SRLR 1089, 06/10/2013.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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