Form ADV

P10 Industries’ Purchase Of RCP Advisors Can Bring 150% Upside

An under-the-radar special situation is emerging with PIOE’s two-part acquisition of RCP Advisors, promising rich rewards over the next several months for investors at these share-prices. RCP Advisors is a large, respected, fast-growing private equity investment management firm; its relevant segments for PIOE oversee $3.6 billion in assets under management (AUM). A conservative-to-average valuation method […]

An Aggressive Hedge Fund Guru

Paul Singer (Trades, Portfolio) runs the oldest hedge fund on Wall Street, one that is now celebrating its 40th anniversary. And his clients have had good reason to stick with him: He has delivered net average annual returns of almost 14%, but there has been a lot of drama along the way. He has been called the […]

Improving Investment Adviser Compliance, Peter B. Driscoll, SEC Acting Director, Office Of Compliance Inspections And Examinations, GIPS Standards Annual Conference, Sept. 14,

Thank you for that kind introduction and for inviting me to speak at this event.Before starting my remarks, let me give the requisite reminder that the views I express today are my own and do not necessarily represent the views of the Commission or its staff.[1] It is a pleasure for me to speak to […]

Revisions to Form ADV

As we previously summarized in September 2016, the SEC has adopted changes to Form ADV, the filing required to be made by nearly all SEC and state-registered investment advisers. These revisions went into effect on October 1, 2017. Among other changes, the updated Form ADV places significant additional reporting requirements on investment advisers who manage separate accounts. […]

John Burbank: Missing Goldilocks’ ‘Just Right’ Porridge

When the 2007 annual results were released, John Burbank (Trades, Portfolio) of Passport Capital was a star. He had racked up a spectacular 219%. He was also the person at the center of another somewhat spectacular event 10 years later: Passport’s assets under management plunged from nearly $6 billion to less than $1 billion in the first two […]

Most Common Advertising Rule Compliance Issues Raised in OCIE Deficiency Letters

As a matter of routine business practice, advisers should review their advertisements and promotional materials to ensure compliance with Rule 206(4)-1 of the Advisers Act. Advisers should also regularly review the adequacy and effectiveness of their compliance programs and procedures. The SEC’s Office of Compliance Inspections and Examinations (OCIE) recently issued a risk alert identifying […]

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 […]

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 […]