The November 4, 2022 deadline for compliance with Rule 204(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940…

The recently proposed Inflation Reduction Act of 2022 (“IRA”) includes a number of tax provisions, the most important of which…

The U.S. Securities and Exchange Commission (the “SEC”) recently proposed extensive new rules and amendments under the Investment Advisers Act…

Back in August 2021 the Securities and Exchange Commission filed a first-of-its-kind “shadow” insider trading case against Matthew Panuwat. Mr….

This is our annual letter briefly reviewing various issues that our investment adviser clients should consider over the next few…

On September 14, 2021, the SEC brought an unusual enforcement action against App Annie, a so-called “alt data” provider, and…

Last month the SEC filed a novel insider trading case worth taking a look at (a link to the SEC…

Gov. Gavin Newsom signed A.B. 150 into law on July 15, 2021. This law creates a workaround to the $10,000…

The U.S. Securities and Exchange Commission (the “SEC”) recently announced in Advisers Act Release 5756 that it has adjusted for…

The majority of insider trading compliance questions this year, by a wide margin, have been related to SPAC PIPE offerings. …

The Securities and Exchange Commission (the “SEC”) has finalized significant revisions to its rules under the Investment Advisers Act governing…

This is our annual letter briefly reviewing various issues that our investment adviser clients should consider over the next few…

The Securities Exchange Commission (the “SEC”) has rescheduled its compliance outreach program’s national seminar for investment companies and investment advisers…

In September and October, the U.S. Bureau of Economic Analysis (“BEA”) is conducting its 2019 Benchmark Survey of Financial Services…

The “accredited investor” definition largely has been unchanged since 1982, but on August 26, 2020, the Securities and Exchange Commission…

Two topics from recent SEC investment adviser enforcement cases, disclosure language and insider trading policies. Adviser Disclosures: What does “may”…

The due dates to prepare, file and deliver a new part of Form ADV, Form CRS (Customer Relationship Summary), are…

As we navigate these unprecedented times, we wanted to share our thoughts about the COVID-19 crisis, and provide some constructive…

Updated March 26, 2020 – On Friday, March 13, 2020, the SEC announced conditional relief for the due dates of…

Clients often ask what the benefits are of registering a trademark. There are many benefits to registering a trademark in…

This is our annual letter briefly reviewing various issues that our investment adviser clients should consider over the next few…

Last October I spoke at a compliance conference on the subject of SEC investment adviser examinations.  The article below is…

FINRA has updated its Rules 5130 and 5131, which govern allocations of “new issues,” effective January 1, 2020.  Broadly speaking,…

Last week the SEC’s Division of Enforcement published its Annual Report for the fiscal year ended September 30, 2019 (available…

Earlier this year, the National Futures Association (NFA) announced that individuals registered as associated persons (APs) of NFA members that…