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 … Continued
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 … Continued
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. … Continued