Does your Investment Adviser Have Effective Procedures to Monitor and Approve Performance Advertisements?
Advertising continues to be one of the primary focus areas of the SEC during investment adviser examinations. More specifically, performance advertising is one of the more common deficiencies found during SEC examinations and one that needs effective compliance oversight. During examinations, the SEC is interested in whether investment advisers have effective policies and procedures to make sure that their claims about past investment performance, their advertisements, and other marketing materials, among other things, contain accurate information, are not misleading, are not promissory, and have been reviewed by compliance.
Unfortunately, SEC Rule 206(4)-1 (Advertisements by Investment Advisers) under the Investment Advisers Act of 1940 provides little guidance on performance advertising. Much of the SEC's guidance is spelled out in no-action letters, with probably the most important one being Clover Capital Management, Inc., and enforcement actions. Investment advisers that regularly advertise performance need be familiar with the parameters outlined in Clover. The importance of Clover is heightened by the fact that the SEC staff, as a matter of policy, does not review specific advertisements except when conducting an examination of an investment adviser.
The following is a general summary of proper performance advertising compliance outlined by the SEC’s Division of Investment Management and Office of Compliance.
The SEC staff has said that, if you advertise your past investment performance record, you should disclose all material facts necessary to avoid any unwarranted inference. For example, SEC staff has indicated that it may view performance data to be misleading if it:
· does not disclose prominently that the results portrayed relate only to a select group of the adviser’s clients, the basis on which the selection was made, and the effect of this practice on the results portrayed, if material;
· does not disclose the effect of material market or economic conditions on the results portrayed (e.g., an advertisement stating that the accounts of the adviser’s clients appreciated in value 25% without disclosing that the market generally appreciated 40% during the same period);
· does not reflect the deduction of advisory fees, brokerage or other commissions, and any other expenses that accounts would have or actually paid;
· does not disclose whether and to what extent the results portrayed reflect the reinvestment of dividends and other earnings;
· suggests or makes claims about the potential for profit without also disclosing the possibility of loss;
· compares model or actual results to an index without disclosing all material facts relevant to the comparison (e.g., an advertisement that compares model results to an index without disclosing that the volatility of the index is materially different from that of the model portfolio); and
· does not disclose any material conditions, objectives, or investment strategies used to obtain the results portrayed (e.g., the model portfolio contains equity stocks that are managed with a view towards capital appreciation).
If your investment adviser utilizes performance advertising, you should attend our webinar, “Approving Performance Advertising,” on Wednesday, January 27, 2010 from 12:00 p.m. to 1:00 p.m. CST to learn more about developing strong compliance policies and procedures for preparing, approving and maintaining records related to performance advertising. During this webinar, our consultants will examine the SEC's advertising rule, the SEC no-actions concerning performance advertising and related SEC enforcement actions. RIA Compliance Consultants will provide best practices and disclosures for investment advisers utilizing performance advertising.
Labels: Advertising, Webinar
posted by bhill at 11:01 AM
Did your Firm Renew for 2010? Don't Forget About Form ADV Annual Amendments
Now that we are into a new year, can you confirm your registered investment advisor and its advisor representatives were properly renewed for 2010? Every year there are always a handful of firms that fail to submit renewal fees through the IARD system in a timely fashion. Therefore, even if you think the renewal payment was sent in time, please make sure your firm retrieves the Final Renewal Statement and confirms it is renewed for calendar year 2010.
The Final Renewal Statement will indicate one of the following.
Paid in Full - If your firm's renewal statement has been paid in full, the renewal process is complete. You should print a copy of the Final Renewal Statement and file it with your firm's books and records.
Outstanding Balance Due or Refund - If your firm paid its Preliminary Renewal Statement in full, but added or removed a state registration or advisor representative during the time period between the posting of Preliminary Renewal Statements and the 2009 shut down period, then your firm will either have additional fees due or receive a credit. If additional fees are due, the fees should be submitted as soon as possible, but must be posted by February 5, 2010. If your firm received a refund, the credit will automatically be transferred to your firm's Daily Account.
Failed to Renew - If a firm's Final Renewal Statement indicates Failed to Renew, FINRA did not receive the total balance due on the Preliminary Renewal Statement prior to the December deadline. In these cases, it is standard operating procedure for FINRA to automatically terminate all advisor representatives of the firm. In addition, over thirty states have given FINRA the authority to automatically terminate a registered investment advisor that does not pay its renewal fees in full. If your firm's statement indicates Failed to Renew, you will need to contact each state jurisdiction immediately to determine an appropriate course of action.
It is important to make sure your registered investment advisor submits all required documentation directly to the states where the firm is registered. If your firm failed to renew through IARD, it is important to take immediate action to rectify the situation. Give us a call to find out more about our re- registration services and pricing.
In addition to confirming your firm's registration renewal for 2010, we would like to remind registered investment advisors of their responsibility to prepare and file their Form ADV Part 1 Annual Amendment. The Annual Amendment must be filed no later than 90 days after a registered investment advisor firm's fiscal year ends. Many registered investment advisors use December 31 as their fiscal year end which results in a March 30, 2010 deadline to submit the Annual Amendment through the IARD system. The Annual Amendment is used to update information such as number of clients, number of accounts, and assets under management. We recommend registered investment advisors closely review the entire Form ADV to confirm all information is correct.
SEC registered firms should be aware that the SEC and FINRA have reinstated the annual IARD Firm System Processing Fee. The fee is assessed for the electronic filing of forms on the IARD system. The IARD Firm System Processing Fee is separate from applicable state Notice Filing fees. It must be paid by SEC registered firm when filing the Annual Amendment. Firms can begin working on the Annual Amendment, but will need to fund their IARD Daily Account before they can submit the Annual Amendment.
Please refer to the following schedule to determine your firm's annual fee and submit payment to your firm's IARD Daily Account. Be sure to fund the Daily Account; do not fund the Renewal Account: (a) for assets under management of less than $25 million, there's a fee of $40; (b) for assets under management between $25 million and $100 million, there's a fee of $150; and (c) for assets under management over $100 million, there's a fee of $200.
Please contact RIA Compliance Consultants, Inc. if you are interested in our Form ADV Annual Amendment services. We would also like to invite you to attend our upcoming webinar on January 14, "Preparing the Form ADV Part 1 Annual Amendment". The registration fee for our webinar is $59.95. During this webinar, RIA Compliance Consultants will discuss the items that must be updated as part of the Form ADV Part 1 Annual Amendment including how securities regulators expect a registered investment advisor to calculate assets under management. In addition, we will review common mistakes when preparing the Form ADV Part 1 Annual Amendment. Finally, we will cover some common examples of material changes that should have been updated to your Form ADV during the past year.
The Final Renewal Statement will indicate one of the following.
Paid in Full - If your firm's renewal statement has been paid in full, the renewal process is complete. You should print a copy of the Final Renewal Statement and file it with your firm's books and records.
Outstanding Balance Due or Refund - If your firm paid its Preliminary Renewal Statement in full, but added or removed a state registration or advisor representative during the time period between the posting of Preliminary Renewal Statements and the 2009 shut down period, then your firm will either have additional fees due or receive a credit. If additional fees are due, the fees should be submitted as soon as possible, but must be posted by February 5, 2010. If your firm received a refund, the credit will automatically be transferred to your firm's Daily Account.
Failed to Renew - If a firm's Final Renewal Statement indicates Failed to Renew, FINRA did not receive the total balance due on the Preliminary Renewal Statement prior to the December deadline. In these cases, it is standard operating procedure for FINRA to automatically terminate all advisor representatives of the firm. In addition, over thirty states have given FINRA the authority to automatically terminate a registered investment advisor that does not pay its renewal fees in full. If your firm's statement indicates Failed to Renew, you will need to contact each state jurisdiction immediately to determine an appropriate course of action.
It is important to make sure your registered investment advisor submits all required documentation directly to the states where the firm is registered. If your firm failed to renew through IARD, it is important to take immediate action to rectify the situation. Give us a call to find out more about our re- registration services and pricing.
In addition to confirming your firm's registration renewal for 2010, we would like to remind registered investment advisors of their responsibility to prepare and file their Form ADV Part 1 Annual Amendment. The Annual Amendment must be filed no later than 90 days after a registered investment advisor firm's fiscal year ends. Many registered investment advisors use December 31 as their fiscal year end which results in a March 30, 2010 deadline to submit the Annual Amendment through the IARD system. The Annual Amendment is used to update information such as number of clients, number of accounts, and assets under management. We recommend registered investment advisors closely review the entire Form ADV to confirm all information is correct.
SEC registered firms should be aware that the SEC and FINRA have reinstated the annual IARD Firm System Processing Fee. The fee is assessed for the electronic filing of forms on the IARD system. The IARD Firm System Processing Fee is separate from applicable state Notice Filing fees. It must be paid by SEC registered firm when filing the Annual Amendment. Firms can begin working on the Annual Amendment, but will need to fund their IARD Daily Account before they can submit the Annual Amendment.
Please refer to the following schedule to determine your firm's annual fee and submit payment to your firm's IARD Daily Account. Be sure to fund the Daily Account; do not fund the Renewal Account: (a) for assets under management of less than $25 million, there's a fee of $40; (b) for assets under management between $25 million and $100 million, there's a fee of $150; and (c) for assets under management over $100 million, there's a fee of $200.
Please contact RIA Compliance Consultants, Inc. if you are interested in our Form ADV Annual Amendment services. We would also like to invite you to attend our upcoming webinar on January 14, "Preparing the Form ADV Part 1 Annual Amendment". The registration fee for our webinar is $59.95. During this webinar, RIA Compliance Consultants will discuss the items that must be updated as part of the Form ADV Part 1 Annual Amendment including how securities regulators expect a registered investment advisor to calculate assets under management. In addition, we will review common mistakes when preparing the Form ADV Part 1 Annual Amendment. Finally, we will cover some common examples of material changes that should have been updated to your Form ADV during the past year.
Labels: Annual Amendment, Form ADV, IARD
posted by bhill at 9:35 AM
Recent Changes Regarding the Series 65 and Series 66 Examinations
Effective January 1, 2010, the North American Securities Administrators Association ("NASAA") has made some changes regarding the composition and the minimum passing score for the Series 65 and Series 66 Examinations.
The Series 65 is the Uniform Investment Adviser Law Examination, which is designed to qualify candidates as investment adviser representatives. The Series 65 Examination will continue to be comprised of 130 questions; however, effective January 1, 2010, the number of questions devoted to Legal and Regulatory Issues will decrease from 45 to 40 and the remaining 90 questions will cover Economic Concepts, including investment products, recommendations, and strategies and may include a few questions on Capital Markets Theory and specific types of accounts, such as College Savings Plans. Additionally, the Examination includes 10 questions which are considered pretest questions, which do not count towards the final grade. Effective January 1, 2010, the passing grade for the Series 65 Examination was increased from 68.5% to 72%.
The Series 66 is the Uniform Combined State Law Examination, which is designed to qualify candidates both as securities agents and investment adviser representatives. The Series 7 is considered a corequisite exam to the Series 66 and is required to be successfully completed in addition to the Series 66 before a candidate can register as a securities agent and investment adviser representative. The composition of the Series 66 Examination was significantly changed. The Series 66 Examination remains comprised of 100 questions; however, the number of questions testing knowledge of Legal and Regulatory Issues has decreased from 80 to 50 and the number of questions testing knowledge of Investment Recommendations, Strategies, and Products has increased from 20 to 50. Additionally, the Examination includes 10 questions which are considered pretest questions, which do not count towards the final grade. Effective January 1, 2010, the passing grade for the Series 66 Examination was increased from 71% to 75%.
The Series 65 is the Uniform Investment Adviser Law Examination, which is designed to qualify candidates as investment adviser representatives. The Series 65 Examination will continue to be comprised of 130 questions; however, effective January 1, 2010, the number of questions devoted to Legal and Regulatory Issues will decrease from 45 to 40 and the remaining 90 questions will cover Economic Concepts, including investment products, recommendations, and strategies and may include a few questions on Capital Markets Theory and specific types of accounts, such as College Savings Plans. Additionally, the Examination includes 10 questions which are considered pretest questions, which do not count towards the final grade. Effective January 1, 2010, the passing grade for the Series 65 Examination was increased from 68.5% to 72%.
The Series 66 is the Uniform Combined State Law Examination, which is designed to qualify candidates both as securities agents and investment adviser representatives. The Series 7 is considered a corequisite exam to the Series 66 and is required to be successfully completed in addition to the Series 66 before a candidate can register as a securities agent and investment adviser representative. The composition of the Series 66 Examination was significantly changed. The Series 66 Examination remains comprised of 100 questions; however, the number of questions testing knowledge of Legal and Regulatory Issues has decreased from 80 to 50 and the number of questions testing knowledge of Investment Recommendations, Strategies, and Products has increased from 20 to 50. Additionally, the Examination includes 10 questions which are considered pretest questions, which do not count towards the final grade. Effective January 1, 2010, the passing grade for the Series 66 Examination was increased from 71% to 75%.
Labels: IAR Licensing, Series 65
posted by bhill at 9:29 AM
House Financial Services Committee Advances Investor Protection Act
Here's our update regarding proposed changes to the regulation of investment advisers.
The Financial Services Committee of the U.S. House of Representatives advanced H.R. 3817, the Investor Protection Act, out of committee yesterday. According to the Financial Services Committee's press release, key provisions of this bill include the following:
The Financial Services Committee of the U.S. House of Representatives advanced H.R. 3817, the Investor Protection Act, out of committee yesterday. According to the Financial Services Committee's press release, key provisions of this bill include the following:
- an independent study of the regulatory structure for the securities industry;
- a doubling of the authorized fund for the U.S. Securities and Exchange Commission ("SEC") over five years;
- a requirement that every financial imtermediary who provides advice will have a fiduciary duty towards the customer; and
- an authorization for the SEC to prohibit mandatory arbitration provisions in customer contracts.
Although there was no reference in the Financial Services Committee's press release concerning the amendment to H.R. 3817 approved last week, which raises assets under management requirement from $25,000,000 to $100,000,000, this amendment will effectively result in many registered investment advisors being regulated at the state instead federal level.
Investment News is reporting that H.R. 3817 advanced out of committee with the controversial amendment that gives Financial Industry Regulatory Authority ("FINRA") regulatory authority over registered investment advisors, which are also dually registered as broker-dealers. According to Investment News, Financial Services Committee Chairman opposes this provision and will offer an amendment during the floor debate to strip out this provision from H.R. 3817.
Once the House releases a mark-up of H.R. 3817 as passed out of committee, RIA Compliance will share with its readers additional details about the proposed legislation.
Labels: Arbitration, Fiduciary, SEC, SRO
posted by bhill at 10:29 PM
2010 IARD Renewal & Form ADV Annual Amendment Requirements
Beginning Monday, November 16, 2009, registered investment advisor firms can access their 2010 Preliminary Renewal Statements via their IARD account. The Preliminary Renewal Statement must be paid, in full, by Friday, December 11, 2009. Because it takes approximately two days for payment to post to the IARD account, the funds should arrive no later than Wednesday, December 09, 2009, to ensure the money is posted to your IARD account by December 11.
RIA Compliance Consultants also wants to remind registered investment advisor firms of their obligation to update Form ADV on at least an annual basis in the form of an Annual Amendment. This is required under U.S. Securities and Exchange Commission ("SEC") Rule 204-1 of the Investment Advisers Act of 1940 and similar rules of state securities regulators. The Form ADV Annual Amendment must be completed within 90 days after a registered investment advisor firm's fiscal year end. Since the majority of investment advisor firms coordinate their fiscal year end with the end of the calendar year, the Form ADV Annual Amendment has become a requirement that must be completed at the beginning of each year for most advisor firms. The main item that must be updated on the Form ADV Annual Amendment is the investment advisor firm's assets under management. Other items such as, but not limited to, the number of accounts, clients, employees, and investment advisor representatives ("IARs") should also be updated. The Form ADV Annual Amendment can also be used to disclose any material changes. Keep in mind, however, that material changes need to be disclosed within 30 days no matter when they take place. Material changes include items such as, but are not limited to, reportable disciplinary and financial disclosures, changes in contact information, changes to custody disclosures and changes due to successions and ownership arrangements.
RIA Compliance Consultants is offering a special package that includes assistance with completing both the annual renewal requirement and filing the Annual Amendment to Form ADV Part 1. For the low price of $450, RIA Compliance Consultants will help your firm confirm its registration status in all necessary jurisdictions and confirm the registration status of all investment advisor representatives for 2010. You will also receive an Annual Amendment Questionnaire for you to complete so that we may prepare and file your Form ADV Part 1 Annual Amendment within the necessary time frame.
Engagements received by RIA Compliance Consultants after November 16 are subject to availability so complete and return the Agreement for Services today! Click below to view the Consulting Agreement for IARD Renewal and Annual Amendment Services.
*If you are an existing hourly retainer client of RIA Compliance Consultants, you do not need to complete the Agreement for Services. Simply contact your lead consultant to sign-up for this service.
**If you are an annual retainer client of RIA Compliance Consultants, this service is included in your retainer agreement. To learn more about our retainer services and fees, please contact us at 877-345-4034.
IARD%20Renewal.Annual%20Amendment.2010.pdf
RIA Compliance Consultants also wants to remind registered investment advisor firms of their obligation to update Form ADV on at least an annual basis in the form of an Annual Amendment. This is required under U.S. Securities and Exchange Commission ("SEC") Rule 204-1 of the Investment Advisers Act of 1940 and similar rules of state securities regulators. The Form ADV Annual Amendment must be completed within 90 days after a registered investment advisor firm's fiscal year end. Since the majority of investment advisor firms coordinate their fiscal year end with the end of the calendar year, the Form ADV Annual Amendment has become a requirement that must be completed at the beginning of each year for most advisor firms. The main item that must be updated on the Form ADV Annual Amendment is the investment advisor firm's assets under management. Other items such as, but not limited to, the number of accounts, clients, employees, and investment advisor representatives ("IARs") should also be updated. The Form ADV Annual Amendment can also be used to disclose any material changes. Keep in mind, however, that material changes need to be disclosed within 30 days no matter when they take place. Material changes include items such as, but are not limited to, reportable disciplinary and financial disclosures, changes in contact information, changes to custody disclosures and changes due to successions and ownership arrangements.
RIA Compliance Consultants is offering a special package that includes assistance with completing both the annual renewal requirement and filing the Annual Amendment to Form ADV Part 1. For the low price of $450, RIA Compliance Consultants will help your firm confirm its registration status in all necessary jurisdictions and confirm the registration status of all investment advisor representatives for 2010. You will also receive an Annual Amendment Questionnaire for you to complete so that we may prepare and file your Form ADV Part 1 Annual Amendment within the necessary time frame.
Engagements received by RIA Compliance Consultants after November 16 are subject to availability so complete and return the Agreement for Services today! Click below to view the Consulting Agreement for IARD Renewal and Annual Amendment Services.
*If you are an existing hourly retainer client of RIA Compliance Consultants, you do not need to complete the Agreement for Services. Simply contact your lead consultant to sign-up for this service.
**If you are an annual retainer client of RIA Compliance Consultants, this service is included in your retainer agreement. To learn more about our retainer services and fees, please contact us at 877-345-4034.
IARD%20Renewal.Annual%20Amendment.2010.pdf
Labels: Annual Amendment, Form ADV, IAR Licensing, IARD, Renewals
posted by bhill at 8:24 PM
Deadline Approaching for Investment Advisers to Complete the New Form U4 Regarding Regulatory Actions
Registered investment adviser firms must file amended Form U4s for all their investment adviser representatives to provide answers to the new regulatory action disclosure questions. The North American Securities Administrators Association ("NASAA") has published notice clarifying that the new questions on the FINRA Form U4 and the deadline of November 13, 2009 applies to investment adviser representatives.
Six regulatory action disclosure questions were added to the Form U4 on May 18, 2009. The new disclosure questions are Questions 14C(6)(7) and (8) and Questions 14E(5)(6) and (7). These questions are recorded with a blank answer on an investment adviser representative’s Form U4 filing, and investment adviser firms must provide answers to these new disclosure questions by not later than November 13, 2009. In order to respond to the new disclosure questions, a firm will need to submit Form U4s with responses to these new questions for all of the firm’s investment adviser representatives. If the firm determines that a “yes” response is required for any of the new disclosure questions, then the U4 filing would need to include a corresponding completed disclosure reporting page regarding the “yes” answer.
For additional details regarding the new Form U4 regulatory action questions, you may review information published on the FINRA website at the Approved Changes to Forms U4 & U5 web page and in the FINRA Regulatory Notice 09-23.
RIA Compliance Consultants, Inc. can help you file updated Form U4s for your investment adviser representatives. If you would like our assistance in updating the Form U4s for your investment adviser representatives, please contact our office at 877-345-4034.
Six regulatory action disclosure questions were added to the Form U4 on May 18, 2009. The new disclosure questions are Questions 14C(6)(7) and (8) and Questions 14E(5)(6) and (7). These questions are recorded with a blank answer on an investment adviser representative’s Form U4 filing, and investment adviser firms must provide answers to these new disclosure questions by not later than November 13, 2009. In order to respond to the new disclosure questions, a firm will need to submit Form U4s with responses to these new questions for all of the firm’s investment adviser representatives. If the firm determines that a “yes” response is required for any of the new disclosure questions, then the U4 filing would need to include a corresponding completed disclosure reporting page regarding the “yes” answer.
For additional details regarding the new Form U4 regulatory action questions, you may review information published on the FINRA website at the Approved Changes to Forms U4 & U5 web page and in the FINRA Regulatory Notice 09-23.
RIA Compliance Consultants, Inc. can help you file updated Form U4s for your investment adviser representatives. If you would like our assistance in updating the Form U4s for your investment adviser representatives, please contact our office at 877-345-4034.
Labels: Customer Complaint, Form U4, IAR Licensing
posted by bhill at 11:49 AM
House Financial Services Committee Votes to Raise Assets Under Management for SEC Registration as Investment Adviser from $25 Million to $100 Million
Investment News is reporting that the Financial Services Committee of the U.S. House of Representatives passed today an amendment to the Investor Protection Act, H.R. 3817, whereby the general assets under management requirement to register with the U.S. Securities and Exchange Commission ("SEC") as an investment adviser would increase from $25 million to $100 million.
This proposed change to the current regulatory structure would make state securities regulators the primary regulator for registered investment advisers with less than one hundred million dollars ($100,000,000) of assets under management (assuming the adviser didn't qualify for exemption to the general AUM requirement). Investment News is also reporting that the Committee passed an amendment to H.R. 3817 authorizing a study of whether investment advisers should be subject to self-regulatory organization.
However, what's unclear is whether the Investor Protection Act, H.R. 3817, has been advanced out of the Financial Services Committee. As of Wednesday evening, it appears the bill is still in mark-up since the website for the Financial Services Committee does not indicate that the Investor Protection Act has been passed by the Committee.
This proposed change to the current regulatory structure would make state securities regulators the primary regulator for registered investment advisers with less than one hundred million dollars ($100,000,000) of assets under management (assuming the adviser didn't qualify for exemption to the general AUM requirement). Investment News is also reporting that the Committee passed an amendment to H.R. 3817 authorizing a study of whether investment advisers should be subject to self-regulatory organization.
However, what's unclear is whether the Investor Protection Act, H.R. 3817, has been advanced out of the Financial Services Committee. As of Wednesday evening, it appears the bill is still in mark-up since the website for the Financial Services Committee does not indicate that the Investor Protection Act has been passed by the Committee.
Labels: Registration, SRO
posted by bhill at 8:26 PM
Private Investment Advisers Registration Act is Passed by House Committee on Financial Services
The Financial Services Committee of the U.S. House of Representatives passed H.R. 3818, the Private Fund Investment Advisers Registration Act, which requires advisers to private funds to register with the U.S. Securities and Exchange Commission ("SEC").
The Wall Street Journal reported that the Committee agreed that private funds managing less than $150 million would be exempt from the SEC registration requirement. The WSJ noted that small business investment companies ("SBICs") subject to the oversight of the U.S. Small Business Administration along with venture capital fund managers will be exempted from SEC registration. However, it appears that private equity funds and single family offices will be required to register with the SEC in the bill passed by the Financial Services Committee. MarketWatch reported that Rep. Susan Kosmas explained that this bill includes a one-year transition period before registration with the SEC is mandatory for private funds.
The next stop for H.R. 3818 is the floor of the U.S. House of Representatives. RIA Compliance Consultants will continue to keep readers abreast of the status of the bill in the House and its counterpart in the Senate.
The Wall Street Journal reported that the Committee agreed that private funds managing less than $150 million would be exempt from the SEC registration requirement. The WSJ noted that small business investment companies ("SBICs") subject to the oversight of the U.S. Small Business Administration along with venture capital fund managers will be exempted from SEC registration. However, it appears that private equity funds and single family offices will be required to register with the SEC in the bill passed by the Financial Services Committee. MarketWatch reported that Rep. Susan Kosmas explained that this bill includes a one-year transition period before registration with the SEC is mandatory for private funds.
The next stop for H.R. 3818 is the floor of the U.S. House of Representatives. RIA Compliance Consultants will continue to keep readers abreast of the status of the bill in the House and its counterpart in the Senate.
Labels: Hedge Funds, Registration
posted by bhill at 10:46 PM
