Customize Those Manuals

posted in: Compliance | 0

At the SEC seminar last week, Rosalind Tyson, director of the SEC’s Los Angeles office, said that firms should design compliance programs tailored to their core business activities and then follow through on them. “For heaven’s sake, don’t adopt policies … Continued

New Massachusetts Regulations

posted in: Registration & Licensing | 0

The Massachusetts Securities Division recently adopted new regulations related to investment advisers.  The new regulations became effective February 3, 2012.  The rules will generally not be enforced until August 3, 2012.  The changes to the regulations did the following: Discretion … Continued

Registration Transition Issue

posted in: Registration & Licensing | 0

Many states require applicant for state registration to complete an affidavit of “no prior activity.” The choices are typically, no, you have not conducted advisory activities in this state or yes, you have conducted advisory activities in this state. If … Continued

Massachusetts Data Privacy Act

posted in: Privacy & Data Security | 0

Please note by March 1, 2012, advisers must ensure their agreements with third-party service providers with which they share personal information meet Massachusetts Data Privacy Act (201 CMR 17) requirements.

New Challenges for Family Offices

posted in: Registration & Licensing | 0

The bombshell in the Dodd-Frank Act for family offices was the revocation of the “less-than-15-client exemption” for private investment advisers. That rule allowed single-family offices to avoid registration with the Securities and Exchange Commission under the Investment Advisers Act of … Continued