Compliance Solutions for Investment Advisers

Monthly Archives: July 2011

Compliance Alert! Performance Fees

Dear Compliance Professional, Dodd-Frank is certainly keeping us all busy. On July 12, 2011, the SEC issued an order adopting changes to the standard for charging clients a performance fee. Background The Advisers Act generally prohibits an investment adviser from entering into, extending, renewing, or performing any investment advisory contract that provides for performance compensation.

Compliance Alert! Calculating Regulatory Assets Under Management

Dear Compliance Professional, The recently adopted SEC rules and rule amendments refer to an adviser’s “regulatory assets under management.” This new terminology distinguishes the assets reported in Form ADV Part 1 from the assets under management disclosure that advisory clients now receive in Part 2A of Form ADV. The changes also provide a uniform method

Compliance Alert! SEC Adopts Amendments to Advisers Act

Dear Compliance Professional, The rules adopted by the SEC last week provided much needed clarity to both the new assets under management (AUM) threshold for SEC registration and the required transition of certain “mid-sized” SEC-registered investment advisers to state registration. This Compliance Alert! will provide an overview of what these new rules mean for all