by James E. Grand | Dec 26, 2016 | In Plain English
AVOIDING A “GENERAL SOLICITATION”—Do’s and Don’ts It is important for hedge fund managers to fully understand the breadth of Regulation D’s prohibition on general solicitation or general advertising. Basically, the prohibition broadly applies to all contacts with...
by James E. Grand | Sep 1, 2016 | In Plain English
The following blog is the third of a 3-part series on this topic. Under the new Fiduciary Rule, when relying on the Best Interest Contract Exemption (“BIC Exemption” or “BICE”), a written contract is required. The contract may be a separate agreement or its required...
by James E. Grand | Sep 1, 2016 | In Plain English
The following blog is the second of a 3-part series on this topic. Part One should be read in conjunction with this overview. This “TO DO” list is for investment advisers that intend to start or continue providing fiduciary investment advice to retirement plan...
by James E. Grand | Sep 1, 2016 | In Plain English
The following blog is the first of a 3-part series on this topic. Parts Two and Three should be read in conjunction with this overview. FACT ONE: Investment advisers generally earn a substantial portion of their fee income managing funds for retirement plan investors....
by James E. Grand | Aug 10, 2016 | In Plain English
In Plain English A publication of THE SECURITIES LAW GROUP | James E. Grand | August 2016 PORTABILITY: Use of Historical Performance at a Predecessor Firm We are often asked by advisers who are switching firms whether they can use in their own performance presentation...
