Inflation. What Inflation?

Reversion to the mean is one of finance’s most tried and true principles. As financial professionals, any time we see an asset class rise to an unsustainable valuation, or a statistical data point reach a level it never has before, we start with the premise it will eventually return to the long-term average. What if […]

CFTC to Delay De Minimis Decision Another Year, Giancarlo Says

Commodity Futures Trading Commission (CFTC) Chairman Christopher Giancarlo said Wednesday he will request the regulatory agency postpone a decision on the de minimis threshold by a year, effectively delaying implementation until the end of 2018. In testimony before the House Committee on Agriculture, Giancarlo said he wants CFTC to “not just resolve” the de minimis […]

Amendments To Form ADV: Practical Considerations

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.1 Among other things, the amended Form requires expanded information regarding the investment activities of separately managed accounts (“SMAs”), standardizes the registration of so-called “relying advisers” operating as […]

Revised Form ADV Began October 1st

Effective October 1, 2017, investment advisers must adhere to amended requirements regarding the investment adviser public disclosure form (Form ADV). The Securities Exchange Commission (the SEC) announced these amendments in 2016. The new Form ADV disclosure requirements apply to both initial and amended Form ADV filings. The amendments can be grouped into three categories: (i) additional […]

Funds Talk: October 2017 – SEC Issues Risk Alert Regarding Advertising Rule Compliance Based on Recent OCIE Examinations

On Sept. 14, 2017, the Securities and Exchange Commission (the “SEC”) issued a risk alert outlining certain compliance issues identified by the regulator’s Office of Compliance Inspections and Examinations (“OCIE”) related to Rule 206(4)-1 (the “Advertising Rule”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The compliance issues addressed in the alert were […]

Investment Adviser Compliance with SEC’s Amended Form ADV

Beginning October 1, 2017, investment advisers filing Form ADV with the Securities and Exchange Commission (the “SEC”) must file using the amended form adopted by the SEC on August 25, 2016 (the “Amended Form ADV”).  According to the staff of the SEC, the Amended Form ADV is intended to modernize and enhance disclosure requirements while […]

CFTC Chair Giancarlo: Embracing Blockchain Is in the ‘National Interest’

That’s according to J. Christopher Giancarlo, chairman of the Commodity Futures Trading Commission (CFTC), who issued the bold proclamation in remarks at a gathering of government technology executives in Washington, D.C. Wednesday morning. But while the blockchain industry has been encouraging regulators and government agencies to embrace the technology for years, this acknowledgment might have more oomph behind […]

Form ADV Changes to Take Effect Next Month

Beginning next month, registered investment advisors (RIA) will have to disclose more details around private funds they manage, separately managed accounts (SMA), social media postings and regulatory assets. The changes take effect Oct. 1 following adoption of the amendments to Form ADV 1A by the Securities & Exchange Commission last year. Advisers filing an initial […]

SS&C GlobeOp’s Regulatory Solutions Group Celebrates Five Year and 500 Client Milestone

SS&C Technologies Holdings, Inc. (Nasdaq: SSNC), a global provider of financial services software and software-enabled services, today announced that the SS&C GlobeOp Regulatory Solutions Group has launched several new high performance solutions designed to improve data and portfolio management, performance reporting, and investment qualification processes for funds and asset managers to complement compliance with global […]

Countdown to New Form ADV – Are You Ready?

October 1st is less than a month away. That’s the effective date for the new Form ADV (Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers). The new form reflects numerous changes adopted by the Securities and Exchange Commission (“SEC”) on August 25, 2016 to improve the quality of the information collected […]

Federal Court Rules Layering Can Be Market Manipulation

The US District Court in New York hearing the enforcement action by the Securities and Exchange Commission against Lek Securities and Samuel Lek, its 70 percent owner and chief executive officer (collectively, the “LEK Defendants”), denied the defendants’ motion to dismiss, ruling that layering and cross-market manipulation as alleged by the SEC in its complaint […]