The recent changes by the U.S. Securities and Exchange Commission (“SEC”) to Rule 206(4)-2 under the Investment Advisers Act of 1940 include an important development for investment advisers that operate so called pooled investment vehicles. Pooled investment vehicle is an SEC term and includes private investments such as limited liability companies and limited partnerships not [...]
Internal Control Report Earlier this month, new requirements under SEC Rule 206(4)-2 of the Investment Advisers Act of 1940 went into effect. The most stringent (and expensive) of these requirements is the new internal control report rule. Investment advisers or their related persons that serve as qualified custodian for investment advisory client funds or securities [...]
Join us for our complimentary webinar, the “The Nuts & Bolts of Registering an Investment Advisor,” on Wednesday, April 21, 2010 at 12:00 p.m. Central. During this webinar, RIA Compliance Consultants will explain in detail the process and documents necessary for registering a firm as an investment advisor, the criteria for determining whether a firm [...]
Yesterday, the Division of Investment Management of the U.S. Securities and Exchange Commission (“SEC”) updated its Staff Responses to Questions About the Custody Rule. In the updated responses, the Division provided guidance for co-trustee arrangements. As a result of the new guidance, we have revised our Investment Adviser Compliance Alert published yesterday. For an updated [...]
Due to overwhelming number of questions and apparent confusion among many federally registered investment advisers, we’ve prepared a complimentary white paper exploring the new custody rule of the United States Securities and Exchange Commission (“SEC”). This white paper provides details regarding the definition of custody, examples of custody and requirements under the new SEC rule. [...]
