by James E. Grand | Jan 1, 2016 | In Plain English
YEAR-END COMPLIANCE MATTERS INVESTMENT ADVISERS AND EXEMPT REPORTING ADVISERS AND CERTAIN FUND MANAGERS IARD Renewal Fees. Annual renewal fees for SEC and state-registered investment advisers as well as SEC exempt reporting advisers were due to the IARD on December...
by James E. Grand | Dec 1, 2015 | In Plain English
The staff of the SEC recently stated that a competent Chief Compliance Officer (“CCO”) must develop in-depth knowledge in nine areas. A CCO must: Have first-hand knowledge of applicable laws and regulations including relevant exemptive orders; Develop a deep...
by James E. Grand | Nov 1, 2015 | In Plain English
The legal issue for investment advisers using public commentaries on social media is an SEC rule called “the testimonial rule.” Although the SEC rules do not define “testimonial,” the staff has consistently interpreted the term to include “a statement of a client’s...
