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Videocast: Asset management regulation in 2020 videocast series – Investment company developments
The CrowdStrike computer failures that swept the globe on Friday, July 18, 2024, and persisted through the weekend may have impacted fund advisers relying on the Windows system, possibly triggering an “operations event” that...more
The Securities and Exchange Commission (“SEC”) adopted amendments to Form N-PX on November 2, 2022. Previously, Form N-PX applied solely to registered investment companies (i.e., mutual funds, exchange-traded funds and...more
Investment managers required to file Form N-PX pursuant to Rule 14Ad-1 of the Securities Exchange Act of 1934, as amended, will face their initial Form N-PX filing deadline on August 31, 2024. Although the filing obligation...more
The US Department of the Treasury (the Treasury), with the assistance of the Board of Governors of the Federal Reserve System and the Federal Reserve Bank of New York, conducts a mandatory benchmark survey every five years. ...more
INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 11, 2023 in order to cover such fees (with a recommendation from...more
This Memorandum is intended to remind you of certain U.S. annual requirements that may be applicable to your business and is divided into five sections. All investment advisers (whether or not registered with the Securities...more
In recent weeks, the U.S. Securities and Exchange Commission (the “SEC”) has kicked off a wholesale transformation in the regulation of the private funds industry. These actions include rule proposals, enforcement actions,...more
The Central Bank of Ireland (the “Central Bank”) sent a communication to the Irish funds industry on 1 December 2021, outlining the timeframes for receipt of: (i) QIAIF authorisations / approvals and notings; (ii) ICAV...more
With the new year comes a number of annual compliance obligations for evaluation by investment fund managers. In addition to the obligation for registered investment advisers to conduct an annual review of their compliance...more
U.S. persons who provided or received any financial services, such as investment advisory services, fund management or brokerage services, to or from non-U.S. persons during 2019 (“Reporters”) must file a Form BE-180 report...more
- The BEA requires all U.S. persons that own or control more than 10 percent of the voting securities of a “foreign” business enterprise to file a report on its BE-10 Benchmark Survey of U.S. Direct Investment Abroad for the...more
As discussed in our prior publication, on March 13, the Securities and Exchange Commission (SEC) issued two orders under the Investment Company Act of 1940 (the Investment Company Act) and the Investment Advisers Act of 1940...more
On 16 September 2019, the Central Bank of Ireland (the “Central Bank”) sent a letter to the Irish funds industry outlining the timeframes for receipt of (i) new fund applications and (ii) post-authorisation amendments that...more
U.S. issuers (including private investment funds such as hedge, private equity and venture capital funds) must report certain data regarding holdings of their securities by non-U.S. residents to the U.S. Treasury via Form TIC...more
Last week, the House of Representatives overwhelmingly passed the “Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019” (H.R. 1994) by a vote of 417-3. The bill makes numerous changes affecting...more
As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 17 in order to cover such fees (with a recommendation from IARD to...more
• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more
On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more
Currently pending amendments to Form ADV have a compliance date of October 1, 2017 and, as of that date, an adviser filing an initial Form ADV or an amendment to an existing Form ADV must use the revised Form ADV. In an...more
- Mandatory reporting required by the Bureau of Economic Analysis on Form BE-10 – 2014 Benchmark Survey of U.S. Direct Investment Abroad - Investment managers, general partners, hedge funds and private equity funds are...more