Dodd-Frank Act Is it really significant?

Size: px
Start display at page:

Download "Dodd-Frank Act Is it really significant?"

Transcription

1 FINANCIAL SERvICES Dodd-Frank Act Is it really significant? Impact of US Regulation on Foreign Investment Managers and Funds May 2011 kpmg.com

2 With as many as 11 federal regulatory agencies required to write nearly 250 new rules during the next year or more, the Dodd-Frank Act will continue to present challenges for financial services firms.

3 Dodd-Frank Act Is it really significant? May 2011 The far-reaching implications of the Dodd-Frank Act on US financial services organisations, has been widely discussed. Clearly these rules are having a direct impact on US firms, but could also mean big changes for foreign firms. With up to 386 rules required to be enacted by the various regulatory agencies, and the rule making falling behind 2011 targets for completion, firms with any business interest in the US are facing a period of significant change and uncertainty. Foreign funds and investment managers will have to reassess how they run their businesses interests, but ultimately the impact of Dodd-Frank has to be assessed in the wider context of global regulatory initiatives, and the specific rules of each jurisdiction firms operate in. The new rules under Dodd-Frank are in various stages of drafting and adoption, but a number are already having a big impact on the investment management and funds industry. Many investment managers will be required to register as investment advisers with the SEC (Securities and Exchange Commission), by 21 July However, the SEC has informally communicated that the deadline for registration will be extended until the first quarter of Proposed regulations to provide additional oversight of market participants and the activities of investment advisers will affect those who trade in OTC derivatives. Executive compensation is an ongoing area of debate. Though rules under Dodd-Frank are less severe than those proposed in the EU, they will still drive increased transparency and more restrictive pay practices. Finally the volcker Rule opens business and recruitment opportunities for the industry, but the price of these is likely to mean increased regulatory scrutiny. This update explores the implications these rules will have for foreign investment and fund managers and what is to come. Investment Adviser Registration Many investment managers, particularly larger ones, operating in the US are now required to register with the SEC. This is a major change for many managers who have taken advantage of certain registration exemptions in the past. All foreign investment managers fall into one of two groups: A. Previously Registered: Those who are already registered with the SEC. These SEC Registered Investment Advisers (RIAs) can remain registered and will be impacted by other emerging rules around executive compensation, OTC derivatives, and others as a result of Dodd-Frank Act requirements. B. Never Registered: Those who were never registered, but had US clients or US investors, and were previously exempt under the Investment Advisers Act of For Group B, the Private Adviser Exemption, previously widely used, has been removed under the Dodd- Frank Act. The two newly adopted exemptions for non-us advisers are either nearly impossible to meet or will still result in some degree of SEC reporting requirement. While technical, these exemptions are important so we set them out in the box. New proposed exemptions: Private Fund Adviser Exemption : A possible exemption for advisers to solely private funds and with less than US$150 million in private fund assets under management in the US. This includes a provision that only assets which are managed from a place of business within the US count towards the US$150 million threshold. Exemption is not available to any adviser that manages any separate accounts for a US client. Foreign Private Adviser Exemption : A possible exemption for foreign advisers who meet ALL the following criteria: 1. No place of business in the US; 2. Has fewer than 15 US advisory clients and US investors in private funds advised by the investment adviser; 3. Has less than US$25 million Assets under Management (AUM) attributable to US clients and US investors in private funds advised; and 4. Does not present itself as an investment adviser to the US public or advise a US registered fund. The impact on Group A Previously registered foreign investment managers will not be impacted by this particular provision of Dodd-Frank, but emerging rules around executive compensation, OTC derivatives, and others which are more broadly applicable to financial institutions could have a large impact. It is anticipated the US SEC will issue the final rules for investment manager registration in advance of 21 July 2012 (the stated deadline for initial registration). However, given registration documents must be submitted no later than 45 days prior to this deadline, and the time needed to become fully compliant with the obligations, the SEC now expects to extend the registration deadline to the first quarter of 2012.

4 Dodd-Frank Act Is it really significant? May 2011 Significant impact on Group B Many foreign investment managers are likely to be caught by US registration rules because their business cannot meet the criteria for the more limited new exemptions. The new exemptions require that an adviser either: 1. Under the Private Fund Manager Exemption, advise assets exclusively through private funds and meet certain Assets under Management (AUM) thresholds; or 2. Under the Foreign Private Adviser Exemption, have fewer than 15 US investors, less than US$25million in AUM from US investors, and have no place of business in the US. As an investment adviser, registration with the US SEC will bring significant levels of work around building and implementing a compliance program and code of ethics, maintenance of extensive books and records, reporting requirements to the SEC, and hiring or designating a chief compliance officer. Another significant challenge to becoming a US RIA is the applicability of the US Custody Rule. For foreign firms that have been registered with the SEC before, the registration process will be familiar. Understanding whether it applies to your organisation and whether its requirements result in the need for a surprise examination of securities held, or even more costly, an Internal Controls Report, is critical. If you are subject to the Custody Rule, it is important that your external auditors are registered with and subject to regular inspection by the Public Company Accounting Oversight Board (PCAOB). They must also be compliant with US SEC Independence rules, which are much more restrictive than Accounting Principles Board (APB) rules. In addition, the financial statements of the underlying funds will likely need to be completed in US Generally Accepted Accounting Principles (US GAAP) and auditing standards. All of these considerations could result in a change in accounting or tax provider and additional pre-approval requirements by the Board. Any foreign investment manager meeting the exemption criteria under the Private Fund Manager Exemption will be considered exempt but will still need to comply with some SEC requirements albeit significantly less onerous than those of a RIA. These requirements are expected to include shortened form ADv reporting, recordkeeping requirements, and potential SEC examination, but will not include the applicability of the US Custody Rule. OTC Derivatives The Commodity Futures Trading Commission (CFTC) and the SEC have proposed regulations to provide additional oversight of market participants and the activities of investment advisers. The proposals would eliminate a registration exemption for commodity pool operators (CPOs 1 ), which include a person that sponsors, solicits participation in, or operates a collective investment vehicle which trades exchange-traded future contracts, options thereon, or commodity options, swaps or other OTC derivatives, or other such commodity interests. This registration exemption was commonly used by sponsors of private investment funds, including hedge funds. The proposals would require CPOs to file new reports on their commodity trading activities. The proposed rules would only allow exemption from registration as a CPO with respect to a pool if interests in the pool are exempt from registration under US Securities Act of 1933 and are not marketed to the public in the US, among other requirements. How are those trading in OTC derivatives impacted? While the largest and most immediate impact will be on the dealers of these derivatives, any end user on the buy-side (e.g. pension funds and investment The largest and most immediate impact will be on the dealers of these derivatives, any end user on the buy-side e.g. pension funds and investment managers will also be impacted. managers) will also be impacted. Under the proposed rules, the OTC derivatives dealers may be forced to comply with daily tracking and monitoring requirements plus data collection and timely reporting of all transactions including those exempt from the mandatory clearing requirements. In addition, they will face operational changes, including additional booking procedures, enhanced and more costly collateral management. All of the new requirements for dealers are expected to impact the processing, pricing, and availability of OTC derivatives which in turn will directly impact trading and thus have an effect on all buy-side market participants. Ultimately, under new regulations the use of OTC derivatives could become more costly and more laborious to execute than ever before. How does this match up with EU regulations from the European Market Infrastructure Regulation (EMIR)? The EU and US have explicitly stated an intention to follow similar paths around OTC derivatives. Currently the US scope combines that of EMIR which proposes moving trades to Central Counterparties (CCPs) and mandates extended transaction reporting, with the trading platform transparency and conduct proposals covered in MiFID 2. After the initial flurry defining policy framework, practical implementation. Progress in both the EU and the US has slowed, noticeably; many market participants expect the US to act ahead of the EU which could impa ct decisions on which jurisdiction you should pursue trading and hedging activities. Executive Compensation Compensation has been a widely discussed issue in the media over the last 12 months, with much speculation around the balance between risk and reward. The EU has been quite prescriptive in its new requirements, whereas the US rules are more generalised focusing on personal liability. A proposed rule on incentivebased compensation arrangements would prohibit financial institutions with more than US$1billion in assets from adopting compensation programs that would expose them to inappropriate risk or material financial loss.

5 A significant impact The rules would apply to registered broker-dealers, RIAs, and insured US branches of foreign banks (as well as all US financial institutions). Incentivebased compensation will mean any variable compensation that serves as an incentive for performance and is paid to executive officers, directors, principal shareholders, or any individuals or groups whose activities may expose the financial institutions to a material financial loss (e.g. traders). The rule requires risks and financial rewards to be balanced but does not include specific provisions on how to achieve this balance, except for larger financial institutions (over US$50 billion in assets) who must defer payment of at least 50 percent of executive officers incentive-based compensation for at least three years. Under the Financial Stability Board s (FSB) Principles for Sound Compensation Practices and amendments to the Capital Requirements Directive, the EU is also addressing the issue of compensation. The concept is the same as in the US; to balance risk and reward, but the EU rules are more narrowly defined and restrictive, including specific rules on salary compensation, variable components of shares and cash, and deferral conditions. A similar set of firms will be affected (asset managers, brokers, and other financial institutions) and the definition of variable compensation is broadly the same, impacting similar employees. However, it is clear that there is a mis-match between the US and EU executive compensation rules which will result in some firms having to apply both sets of standards. Fund managers that face the European Alternative Investment Fund Managers Directive (AIFMD) will also be faced by stricter remuneration requirements as of 2013 when the Directive comes into force. Volcker Rule From April 2011, the volcker Rule provisions came into effect. These prohibit US banking entities from engaging in proprietary trading of certain financial instruments, and from investing in or sponsoring hedge funds or private equity funds within very limited parameters. The immediate impact on foreign investment managers and funds is likely to be significant. What does this mean for foreign markets? US banking entities will have two years to bring their activities into compliance under the volcker Rule, however the impact on the global investment management and funds industry is immediate. Banks are seeking to dispose of their proprietary trading desks and industry players in order to identify market opportunities. This could widen the talent pool available to investment managers but at what cost and increased regulatory scrutiny? What s Next? With as many as 11 federal regulatory agencies required to write nearly 250 new rules during the next year or more, the Dodd-Frank Act will continue to present challenges for financial services firms. Although the current focus for investment managers and funds is on investment adviser registration, the regulation of OTC derivatives, and executive compensation, other rules are being developed to address the concern over systemic risk and consumer protection. As new rules are released, it is critical that those in the foreign investment management and funds industry monitor and assess the impact for their business, and consider these alongside other key regulatory change initiatives to develop a coherent strategic and operational response. 1. In practice, a CPO is usually the general partner of a limited partnership, the managing member of a limited partnership, the managing member of a limited liability company, the directors of a corporation, the trustees of a trust, or the investment adviser of a non-us company.

6 Contact us Tom Brown Gerard Gaultry Nathalie Dogniez Head of Investment Management, Partner, Financial Services Partner, Financial Services EMA region KPMG in France KPMG in Luxembourg KPMG in the UK T: T: T: E: E: E: Markus Schunk Robert Mirsky Jeroen Van Nek Partner, Financial Services UK Head of Hedge Funds Partner, Financial Services KPMG in Switzerland KPMG in the UK KPMG in the Netherlands T: T: T: E: E: E: Antony Rocker Gerold Hornschu Jonathan Thompson Global Head of Infrastructure Partner, Financial Services Head of Real Estate Investment KPMG in Germany KPMG in the UK T: T: T: E: E: E: Katie D Angelo John Schneider Iain Bannatyne Senior Manager Partner, Investment Partner, Private Equity Group KPMG in the UK Management Regulatory KPMG in the UK T: KPMG in the US T: E: katie.d T: E: E: Giles Williams Jim Low Partner, Financial Services Partner, Financial Services Regulatory Centre of Excellence, Regulatory Centre of Excellence, EMA region Americas region KPMG in the UK KPMG in the US T: T: E: E: The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation KPMG International Cooperative ( KPMG International ), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved. The KPMG name, logo and cutting through complexity are registered trademarks or trademarks of KPMG International. Produced by KPMG s Global Financial Services Practice in the UK. Designed by Mytton Williams Publication name: Dodd-Frank Act Is it really significant? Publication number: Publication date: May 2011

A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act

A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act To view our other A Closer Look pieces on Dodd-Frank, please visit www.pwcregulatory.com The first in an ongoing series Impact

More information

Dodd-Frank Act Changes Affecting Private Fund Managers and Other Investment Advisers By Adam Gale and Garrett Lynam

Dodd-Frank Act Changes Affecting Private Fund Managers and Other Investment Advisers By Adam Gale and Garrett Lynam Dodd-Frank Act Changes Affecting Private Fund Managers and Other Investment Advisers By Adam Gale and Garrett Lynam I. Introduction The Dodd-Frank Wall Street Reform and Consumer Protection Act ( Dodd-Frank

More information

FS Regulatory Brief. How the SEC s Custody Rule Impacts Private Fund Advisers. Introduction. The Custody Rule: An overview

FS Regulatory Brief. How the SEC s Custody Rule Impacts Private Fund Advisers. Introduction. The Custody Rule: An overview How the SEC s Custody Rule Impacts Private Fund Advisers Introduction Under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank, or the Act ) and rules recently adopted by the Securities

More information

U.S. DERIVATIVES REFORM (DODD-FRANK ACT, TITLE VII)

U.S. DERIVATIVES REFORM (DODD-FRANK ACT, TITLE VII) FREQUENTLY ASKED QUESTIONS U.S. DERIVATIVES REFORM (DODD-FRANK ACT, TITLE VII) INTERNAL USE ONLY Comprehensive information for Relationship Managers and other staff of Julius Baer Group September 2015

More information

PROPOSED SEC RULES COULD LIMIT CARRIED INTEREST AND INCENTIVE COMPENSATION PAID BY PRIVATE EQUITY FIRMS

PROPOSED SEC RULES COULD LIMIT CARRIED INTEREST AND INCENTIVE COMPENSATION PAID BY PRIVATE EQUITY FIRMS PROPOSED SEC RULES COULD LIMIT CARRIED INTEREST AND INCENTIVE COMPENSATION PAID BY PRIVATE EQUITY FIRMS Elizabeth Pagel Serebransky, Michael P. Harrell, Jonathan F. Lewis and Charity Brunson Wyatt* While

More information

FS Regulatory Brief. New reporting requirements for exempt reporting advisers Some practical considerations. Who is an exempt reporting adviser?

FS Regulatory Brief. New reporting requirements for exempt reporting advisers Some practical considerations. Who is an exempt reporting adviser? New reporting requirements for exempt reporting advisers Some practical considerations Introduction In June, the Securities and Exchange Commission (SEC) adopted final rules as mandated by the Dodd-Frank

More information

A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act

A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act To view our other A Closer Look pieces on Dodd-Frank, please visit www.pwcregulatory.com Part of an ongoing series Impact On

More information

Derivatives. Capital Markets

Derivatives. Capital Markets Capital Markets 1 Derivatives (This is a summary of this topic. For more in-depth information, see Regulation of Over-the-Counter Derivatives Under the Dodd-Frank Wall Street Reform and Consumer Protection

More information

Regulatory Practice Letter

Regulatory Practice Letter Financial Services Regulatory Practice Regulatory Practice Letter RPL Number 10-13 ADVISORY Dodd-Frank Act: Regulation of Over-the-Counter Derivatives (Title VII) Executive Summary On July 21, 2010, the

More information

Private Investment Funds Alert

Private Investment Funds Alert Private Investment Funds Alert A U G U S T 2 0 1 1 Impact of Final Dodd-Frank Rules on the Regulation of Federal and Connecticut Investment Advisers Questions? If you would like to discuss this article

More information

Investment Adviser Annual and Other Compliance Matters

Investment Adviser Annual and Other Compliance Matters 2013 Investment Adviser Annual and Other Compliance Matters This annual memorandum provides clients and friends of Finn Dixon & Herling with brief summaries of selected compliance matters relevant to investment

More information

SEC Adopts Rules to Implement the Private Fund Investment Advisers Registration Act

SEC Adopts Rules to Implement the Private Fund Investment Advisers Registration Act SEC Adopts Rules to Implement the Private Fund Investment Advisers Registration Act Jason E. Brown and Joel A. Wattenbarger of Ropes & Gray LLP On June 22, 2011, the Securities and Exchange Commission

More information

Title VII: Derivatives (Wall Street Transparency and Accountability Act of 2010)

Title VII: Derivatives (Wall Street Transparency and Accountability Act of 2010) Title VII: Derivatives (Wall Street Transparency and Accountability Act of 2010) Summary: Regulates the previously unregulated, over-the-counter (OTC) derivatives market Requires registration of swap dealers,

More information

Final Foreign Private Adviser and Private Fund Adviser Rules Issued by the U.S. Securities and Exchange Commission.

Final Foreign Private Adviser and Private Fund Adviser Rules Issued by the U.S. Securities and Exchange Commission. July 2011 Final Foreign Private Adviser and Private Fund Adviser Rules Issued by the U.S. Securities and Exchange Commission. Contents Implications for Non-U.S. Investment Advisers On June 22, 2011, the

More information

Investment Management: Rising to the Risk and Compliance Challenge kpmg.com

Investment Management: Rising to the Risk and Compliance Challenge kpmg.com KPMG Regulatory Risk and Compliance Practice Investment Management: Rising to the Risk and Compliance Challenge kpmg.com CONTENTS New Regulatory Frontiers: Forging Ahead in a Changing Landscape 1 A Proactive

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT The Volcker Rule: The End of Proprietary Trading? October 13, 2011 This week in the United States, the Federal Reserve Board, the Office of the Comptroller of the Currency,

More information

Private Equity Groups: Don t Get Caught in a Tangled Web of Regulations

Private Equity Groups: Don t Get Caught in a Tangled Web of Regulations Private Equity Groups: Don t Get Caught in a Tangled Web of Regulations Background The complexity and rate of change for compliance requirements for financial service entities have increased dramatically

More information

Launching a HEDGE FUND in 2015: KEY STRUCTURAL AND OPERATIONAL ISSUES

Launching a HEDGE FUND in 2015: KEY STRUCTURAL AND OPERATIONAL ISSUES Launching a HEDGE FUND in 2015: KEY STRUCTURAL AND OPERATIONAL ISSUES FUND FORMATION SERVICES What sort of legal structure should be used? Most domestic hedge funds are organized as limited partnerships

More information

SPOTLIGHT ON. Registration Requirements and Filings for Investment Advisors and Their Employees

SPOTLIGHT ON. Registration Requirements and Filings for Investment Advisors and Their Employees SPOTLIGHT ON Registration Requirements and Filings for Investment Advisors and Their Employees The contents of this Spotlight have been prepared for informational purposes only, and should not be construed

More information

Starting a Forex Fund

Starting a Forex Fund Starting a Forex Fund By Hannah M. Terhune, Esquire 2008, Capital Management Services Group Market conditions have never been better for setting up a forex fund. The number of forex funds and corresponding

More information

Regulatory Practice Letter December 2013 RPL 13-21

Regulatory Practice Letter December 2013 RPL 13-21 Regulatory Practice Letter December 2013 RPL 13-21 Prohibitions and Restrictions on Proprietary Trading and Relationships with Hedge Funds and Private Equity Funds (Volcker Rule) - Final Rule Executive

More information

The Dodd-Frank Act: Could there be Accounting Consequences?

The Dodd-Frank Act: Could there be Accounting Consequences? The Americas Financial Services Regulatory Center of Excellence Dodd-Frank Accounting Consequences The Dodd-Frank Act: Could there be Accounting Consequences? The Dodd-Frank Wall Street Reform and Consumer

More information

The Volcker Rule Prohibition on Proprietary Trading: Considerations for Broker-Dealer Affiliates of Foreign Banking Organizations

The Volcker Rule Prohibition on Proprietary Trading: Considerations for Broker-Dealer Affiliates of Foreign Banking Organizations Client Alert January 9, 2014 The Volcker Rule Prohibition on Proprietary Trading: Considerations for Broker-Dealer Affiliates of Foreign Banking Organizations The Volcker Rule imposes significant restrictions

More information

The Volcker Rule. Financial Institutions

The Volcker Rule. Financial Institutions Financial Institutions 1 The Volcker Rule The Volcker Rule 1 prohibits an insured depository institution and its affiliates from: engaging in proprietary trading ; acquiring or retaining any equity, partnership,

More information

HOW HEDGE FUNDS ARE STRUCTURED

HOW HEDGE FUNDS ARE STRUCTURED HOW HEDGE FUNDS ARE STRUCTURED Contents Executive Summary A hedge fund is an investment vehicle that can employ a wide range of investment and trading activities to maximize performance returns while minimizing

More information

Client Alert The Volcker Rule Proprietary Trading Prohibition:

Client Alert The Volcker Rule Proprietary Trading Prohibition: North America Banking & Finance Client Alert The Volcker Rule Proprietary Trading Prohibition: January 2014 A Primer for Nonfinancial Company CFOs and Treasurers Prepared by: Daniel L. Goelzer + 1 202

More information

HEDGE FUND FORMATION AND SECURITIES LAW COMPLIANCE

HEDGE FUND FORMATION AND SECURITIES LAW COMPLIANCE THE JIN LAW GROUP A Specialized Corporate & Securities Law Boutique CLIENT TRAINING MATERIAL HEDGE FUND FORMATION AND SECURITIES LAW COMPLIANCE Contents I. Defining Hedge Fund... 2 II. Legal Structure...

More information

Investment Advisers Act of 1940

Investment Advisers Act of 1940 Investment Advisers Act of 1940 Robert Bramnik August 2014 2014 Duane Morris LLP. All Rights Reserved. Duane Morris is a registered service mark of Duane Morris LLP. Duane Morris Firm and Affiliate Offices

More information

SEC ADOPTS FINAL RULES TO THE INVESTMENT ADVISERS ACT OF 1940 IMPLEMENTING PROVISIONS OF THE DODD FRANK ACT

SEC ADOPTS FINAL RULES TO THE INVESTMENT ADVISERS ACT OF 1940 IMPLEMENTING PROVISIONS OF THE DODD FRANK ACT SEC ADOPTS FINAL RULES TO THE INVESTMENT ADVISERS ACT OF 1940 IMPLEMENTING PROVISIONS OF THE DODD FRANK ACT 1. INTRODUCTION On 22 June 2011, the Securities and Exchange Commission ("SEC") adopted final

More information

Broker-dealer industry update

Broker-dealer industry update Highlights of recent accounting and regulatory issues This document highlights key accounting and regulatory issues, new developments and best practices for broker-dealers from the SEC, Public Accounting

More information

Hedge Fund and Private Equity Fund Sponsorship and Investments Under the Proposed Regulations

Hedge Fund and Private Equity Fund Sponsorship and Investments Under the Proposed Regulations The Volcker Rule 1 Hedge Fund and Private Equity Fund Sponsorship and Investments Under the Proposed Regulations The Volcker Rule prohibits a banking entity from sponsoring or investing in a hedge fund

More information

Dodd Frank: Investment Advisers and Pooled Investment Vehicles

Dodd Frank: Investment Advisers and Pooled Investment Vehicles Dodd Frank: Investment Advisers and Pooled Investment Vehicles Bridge Group May 13, 2011 Laurence V. Parker, Jr. Background Investment Advisers Act traditionally regulated money managers managing investments

More information

Changes to Broker-Dealer Reporting & Auditing Requirements

Changes to Broker-Dealer Reporting & Auditing Requirements Changes to Broker-Dealer Reporting & Auditing Requirements Reporting and auditing requirements for broker-dealers changed significantly starting June 1, 2014. These changes are the culmination of several

More information

TESTIMONY OF MARK P. WETJEN ACTING CHAIRMAN, COMMODITY FUTURES TRADING COMMISSION BEFORE THE U.S. HOUSE COMMITTEE ON FINANCIAL SERVICES WASHINGTON, DC

TESTIMONY OF MARK P. WETJEN ACTING CHAIRMAN, COMMODITY FUTURES TRADING COMMISSION BEFORE THE U.S. HOUSE COMMITTEE ON FINANCIAL SERVICES WASHINGTON, DC TESTIMONY OF MARK P. WETJEN ACTING CHAIRMAN, COMMODITY FUTURES TRADING COMMISSION BEFORE THE U.S. HOUSE COMMITTEE ON FINANCIAL SERVICES WASHINGTON, DC February 5, 2014 Good morning Chairman Hensarling,

More information

The US Private Equity Fund Compliance Guide

The US Private Equity Fund Compliance Guide The US Private Equity Fund Compliance Guide How to register and maintain an active and effective compliance program under the Investment Advisers Act of 1940 Executive Summary Edited by Charles Lerner,

More information

Table of content. MiFID II: getting ready for implementation

Table of content. MiFID II: getting ready for implementation Table of content MiFID II: getting ready for implementation The European Council adopted a set of legislation on 13 May 2014 regulating the trade in financial instruments and the investment services sector.

More information

Attracting pension plan assets What alternative investment managers need to know

Attracting pension plan assets What alternative investment managers need to know www.pwc.com/us/assetmanagement Attracting pension plan assets What alternative investment managers need to know February 2012 At a glance Retirement plan sponsors are continuing to give alternative investments,

More information

Deutsche Bank Corporate Banking & Securities

Deutsche Bank Corporate Banking & Securities Deutsche Bank Corporate Banking & Securities ISDA Cross-Border Swaps Representation Letter Fact Sheet 1 October 8, 2013 (Updated April 2015) 1. What is the ISDA Cross-Border Swaps Representation Letter

More information

REED SMITH LLP INVESTMENT ADVISER NEWS QUARTERLY UPDATE

REED SMITH LLP INVESTMENT ADVISER NEWS QUARTERLY UPDATE 4th Quarter 2004 REED SMITH LLP INVESTMENT ADVISER NEWS QUARTERLY UPDATE The Investment Adviser News features regulatory and other news items of interest to the investment management industry and investment

More information

MiFID II Level 2 and energy trading:

MiFID II Level 2 and energy trading: MiFID II Level 2 and energy trading: How to further specify the ancillary activity exemption in Article 2? 17 April 2015 1. Introduction The undersigned associations believe that open, robust, liquid,

More information

Guidance for companies, trusts and partnerships on completing a self-certification form

Guidance for companies, trusts and partnerships on completing a self-certification form Guidance for companies, trusts and partnerships on completing a self-certification form In order to combat tax evasion by both individuals and businesses, the UK and many other countries have entered into

More information

DECEMBER 8, 2010 FINANCIAL MARKETS UPDATE. SEC Proposes Rules Exempting Certain Private Fund Advisers from Investment Adviser Registration.

DECEMBER 8, 2010 FINANCIAL MARKETS UPDATE. SEC Proposes Rules Exempting Certain Private Fund Advisers from Investment Adviser Registration. December 8, 2010 FINANCIAL MARKETS UPDATE SEC Proposes Rules Exempting Certain Private Fund Advisers from Investment Adviser Registration The Securities and Exchange Commission (the SEC ) has published

More information

Most registered investment advisers have now been

Most registered investment advisers have now been By Nabil Sabki and Nadia Sager Private funds are issuers that rely on the Section 3(c)(1) or 3(c)(7) exemptions from registration as investment companies under the Investment Company Act of 1940. Private

More information

Private Equity Alert

Private Equity Alert February 12, 2013 Private Equity Alert Periodic Regulatory Filings and Annual Compliance Obligations Applicable to Private Fund Sponsors by Venera Ziegler There have been many changes to the regulatory

More information

January 24, 2011 VIA EMAIL. Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, D.C.

January 24, 2011 VIA EMAIL. Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. VIA EMAIL Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-1090 Re: Rules Implementing Amendments to the Investment Advisers Act of 1940; File

More information

Automatic Exchange of Information

Automatic Exchange of Information Automatic Exchange of Information The Common Reporting Standard: helping clients kpmg.com Building on FATCA: getting ready for the Common Reporting Standard The Organisation for Economic Co-operation and

More information

U.S. Securities and Exchange Commission

U.S. Securities and Exchange Commission U.S. Securities and Exchange Commission Annual Staff Report Relating to the Use of Data Collected from Private Fund Systemic Risk Reports This is a report of the Staff of the Division of Investment Management

More information

Private Fund Investment Advisers

Private Fund Investment Advisers Financial Institutions 1 Private Fund Investment Advisers Title IV of the Dodd-Frank Act provides for a number of changes to the regulatory regime governing investment advisers and private funds. Among

More information

NO-ACTION RELIEF FOR COMPRESSION EXERCISE SWAPS AND COMPO EQUITY SWAPS COMPRESSION EXERCISE SWAPS. De Minimis Exception Generally

NO-ACTION RELIEF FOR COMPRESSION EXERCISE SWAPS AND COMPO EQUITY SWAPS COMPRESSION EXERCISE SWAPS. De Minimis Exception Generally CLIENT UPDATE NO-ACTION RELIEF FOR COMPRESSION EXERCISE SWAPS AND COMPO EQUITY SWAPS NEW YORK Byungkwon Lim blim@debevoise.com Emilie T. Hsu ehsu@debevoise.com Aaron J. Levy ajlevy@debevoise.com On December

More information

THE SEC S NEW DODD-FRANK ADVISERS ACT RULEMAKING: AN ANALYSIS OF THE SEC S IMPLEMENTATION OF TITLE IV OF THE DODD-FRANK ACT

THE SEC S NEW DODD-FRANK ADVISERS ACT RULEMAKING: AN ANALYSIS OF THE SEC S IMPLEMENTATION OF TITLE IV OF THE DODD-FRANK ACT THE SEC S NEW DODD-FRANK ADVISERS ACT RULEMAKING: AN ANALYSIS OF THE SEC S IMPLEMENTATION OF TITLE IV OF THE DODD-FRANK ACT Kenneth W. Muller, Jay G. Baris and Seth Chertok* The Investment Advisers Act

More information

ADVISORY Dodd-Frank Act

ADVISORY Dodd-Frank Act ADVISORY Dodd-Frank Act July 21, 2010 ADVISERS TO PRIVATE INVESTMENT FUNDS On July 21, 2010, President Obama signed into law the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act). The

More information

Flash News. European Parliament adopts MiFID II. 1. Background. 2. MiFID II for banks, investment firms and asset managers

Flash News. European Parliament adopts MiFID II. 1. Background. 2. MiFID II for banks, investment firms and asset managers www.pwc.lu/regulatory-compliance Flash News European Parliament adopts MiFID II 23 April 2014 Following the political agreement reached on 14 January 2014 by the European Parliament, the Council and the

More information

Commodity Pool Regula0on

Commodity Pool Regula0on Commodity Pool Regula0on Regulation Background Historically, securitization vehicles entered into swaps without being subject to regulation by the Commodity Futures Trading Commission (the CFTC ) as commodity

More information

Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc.

Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc. Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc.gov Final Rules Regarding Further Defining Swap Dealer, Major Swap

More information

By David Mainzer. October 2010

By David Mainzer. October 2010 By David Mainzer October 2010 One effect of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act ), which came into effect on July 21, 2010, is expected to be an increase the

More information

The Dodd-Frank Act: Impact on Investment Advisers

The Dodd-Frank Act: Impact on Investment Advisers The Dodd-Frank Act: Impact on Investment Advisers by Scot E. Draeger and Caleb C.B. DuBois May 2, 2012 100 Middle Street, Portland, ME 04104 207 774-1200 bernsteinshur.com Table of Contents Page About

More information

Swap Dealer Definition: Who's In, Who's Out, and What's Next?

Swap Dealer Definition: Who's In, Who's Out, and What's Next? Swap Dealer Definition: Who's In, Who's Out, and What's Next? Kenneth Raisler Sullivan & Cromwell LLP Edward Rosen Cleary Gottlieb Steen & Hamilton Slide 1 Disclaimer Please note that the information presented

More information

U.S. COMMODITY FUTURES TRADING COMMISSION

U.S. COMMODITY FUTURES TRADING COMMISSION U.S. COMMODITY FUTURES TRADING COMMISSION Three Lafayette Centre 1155 21st Street, NW, Washington, DC 20581 Telephone: (202) 418-5977 Facsimile: (202) 418-5407 www.cftc.gov Division of Swap Dealer and

More information

OVERVIEW AND COMPLEXITY OF CHANGING REGULATORY REQUIREMENTS. Eileen T. Flaherty Global Head of Compliance and Financial Crime Prevention

OVERVIEW AND COMPLEXITY OF CHANGING REGULATORY REQUIREMENTS. Eileen T. Flaherty Global Head of Compliance and Financial Crime Prevention OVERVIEW AND COMPLEXITY OF CHANGING REGULATORY REQUIREMENTS Eileen T. Flaherty Global Head of Compliance and Financial Crime Prevention Structure of Newedge Newedge Group SA is a global broker in derivatives

More information

CONTENTS OF COMPLIANCE PROGRAM MINIMUM REQUIREMENTS Written polices and procedures reasonably designed to document, describe, monitor, and limit all

CONTENTS OF COMPLIANCE PROGRAM MINIMUM REQUIREMENTS Written polices and procedures reasonably designed to document, describe, monitor, and limit all PROGRAM REQUIREMENT Each banking entity must develop and provide for the continued administration of a compliance program reasonably designed to ensure and monitor compliance with the prohibitions and

More information

INVESTMENT FUNDS. SEC Proposes First Dodd-Frank Investment Advisers Act Rule to Address Family Offices. What Is a Family Office?

INVESTMENT FUNDS. SEC Proposes First Dodd-Frank Investment Advisers Act Rule to Address Family Offices. What Is a Family Office? OCTOBER 22, 2010 INVESTMENT FUNDS SEC Proposes First Dodd-Frank Investment Advisers Act Rule to Address Family Offices Section 409(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the

More information

The Alternative Investment Fund Managers Directive ( AIFMD )

The Alternative Investment Fund Managers Directive ( AIFMD ) The Alternative Investment Fund Managers Directive ( AIFMD ) The alternative investment funds industry is shortly to be subject to European authorisation and conduct of business requirements for the first

More information

i-cthru Inc. Form ADV Part 2A Client Brochure

i-cthru Inc. Form ADV Part 2A Client Brochure i-cthru Inc. Tamarind Hill Road 33 Upper Prince s Quarter Saint Maarten, Dutch Caribbean Mailing address 1562 First Ave # 205-2863 New York, NY 10028-4004 USA http://www.i-cthru.com Form ADV Part 2A Client

More information

Understanding RAUM How to interpret the SEC s new metric

Understanding RAUM How to interpret the SEC s new metric How to interpret the SEC s new metric Managed Funds Association March 2012 What is happening? On March 31 2012, newly available public records (Form ADV) will report Regulatory Assets Under Management

More information

Regulatory Compliance for Energy and Commodity Companies

Regulatory Compliance for Energy and Commodity Companies TRIPLE POINT SOLUTION BRIEF Regulatory Compliance for Energy and Commodity Companies COMMODITY XL MEET REQUIREMENTS FOR DODD-FRANK AND EUROPEAN UNION LEGISLATION TRIPLE POINT TECHNOLOGY TPT.COM MARKET

More information

Please find below our responses to the questions raised in the consultation document.

Please find below our responses to the questions raised in the consultation document. 9 May 2014 To: Unit G3 Securities Markets DG Internal Market and Services European Commission Via e-mail to MARKT-G3@ec.europa.eu Re: Consultation Document FX Financial Instruments Dear Sir, Dear Madam,

More information

Private Offerings to U.S. Investors by Non-U.S. Investment Funds: A Post Dodd-Frank Update

Private Offerings to U.S. Investors by Non-U.S. Investment Funds: A Post Dodd-Frank Update INVESTMENT FUNDS CLIENT PUBLICATION July 18, 2011... Private Offerings to U.S. Investors by Non-U.S. Investment Funds: A Post Dodd-Frank Update... As globalization of the private equity and hedge fund

More information

Ropes & Gray Attorneys Discuss the Impact on Private Fund Managers of Final Regulations Under the Volcker Rule

Ropes & Gray Attorneys Discuss the Impact on Private Fund Managers of Final Regulations Under the Volcker Rule Vol. 7, No. 10 March 13, 2014 VOLCKER RULE Ropes & Gray Attorneys Discuss the Impact on Private Fund Managers of Final Regulations Under the Volcker Rule By Vincent Pitaro On December 10, 2013, federal

More information

Client Alert July 21, 2010

Client Alert July 21, 2010 Corporate & Securities North America Client Alert July 21, 2010 For additional information, please see our Dodd-Frank Wall Street Reform And Consumer Protection Act website at http://www.bakermckenzie.com/fin

More information

By Myles J. Edwards, Esq. & Teresa Cooper. Introduction. The Dodd Frank Act ( DFA ) 1

By Myles J. Edwards, Esq. & Teresa Cooper. Introduction. The Dodd Frank Act ( DFA ) 1 The 3 R s : Registration, Reporting and Recordkeeping for Investment Advisers, Private Funds and NFA Members: How The Dodd-Frank Act Forever Changed the Regulatory Landscape By Myles J. Edwards, Esq. &

More information

Supporting Statement for the. (Proprietary Trading and Certain Interests in and Relationships with Covered Funds) (Reg VV; OMB No.

Supporting Statement for the. (Proprietary Trading and Certain Interests in and Relationships with Covered Funds) (Reg VV; OMB No. Supporting Statement for the Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation VV (Proprietary Trading and Certain Interests in and Relationships with Covered Funds) (Reg

More information

Roche Capital Market Ltd Financial Statements 2014

Roche Capital Market Ltd Financial Statements 2014 Roche Capital Market Ltd Financial Statements 2014 1 Roche Capital Market Ltd - Financial Statements 2014 Roche Capital Market Ltd, Financial Statements Roche Capital Market Ltd, statement of comprehensive

More information

Selected EU Regulatory Developments. Lugano Fund Forum, 23rd November 2015 Delphine Calonne, Senior Legal Counsel SFAMA

Selected EU Regulatory Developments. Lugano Fund Forum, 23rd November 2015 Delphine Calonne, Senior Legal Counsel SFAMA Selected EU Regulatory Developments Lugano Fund Forum, 23rd November 2015 Delphine Calonne, Senior Legal Counsel SFAMA Table of contents I. EMIR / FMIA II. MiFID II III. AIFMD IV. UCITS V EMIR / FMIA Why

More information

Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc.

Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc. Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc.gov Interpretive Guidance and Policy Statement Regarding Compliance

More information

A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act

A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act A Closer Look The Dodd-Frank Wall Street Reform and Consumer Protection Act To view our other A Closer Look pieces on Dodd-Frank, please visit www.pwcregulatory.com Part of an ongoing series Incentive-Based

More information

Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc.

Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc. Commodity Futures Trading Commission Office of Public Affairs Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 www.cftc.gov CFTC Division of Market Oversight Responds to Frequently Asked

More information

Solomon Hess SBA Management LLC 4301 North Fairfax Drive Arlington VA 22203 703.356.3333 www.solomonhess.com March 19, 2014

Solomon Hess SBA Management LLC 4301 North Fairfax Drive Arlington VA 22203 703.356.3333 www.solomonhess.com March 19, 2014 Item 1 Cover Page Solomon Hess SBA Management LLC 4301 North Fairfax Drive Arlington VA 22203 703.356.3333 www.solomonhess.com March 19, 2014 Form ADV, Part 2; our Disclosure Brochure or Brochure as required

More information

Client Update Compensation Practices at Financial Institutions Targeted: Proposed Incentive Compensation Rules Aim to Curb Excessive Risk-Taking

Client Update Compensation Practices at Financial Institutions Targeted: Proposed Incentive Compensation Rules Aim to Curb Excessive Risk-Taking 1 Client Update Compensation Practices at Financial Institutions Targeted: Proposed Incentive Compensation Rules Aim to Curb Excessive Risk-Taking NEW YORK Michael P. Harrell mpharrell@debevoise.com Beth

More information

January 5, 2010. To Our Clients and Friends:

January 5, 2010. To Our Clients and Friends: HOW THE SEC S NEW CUSTODY REQUIREMENTS CHANGE THE GROUND RULES FOR REGISTERED INVESTMENT ADVISERS January 5, 2010 To Our Clients and Friends: As 2009 closed, the Securities and Exchange Commission (the

More information

Specializing in Broker Dealer firms since 1996

Specializing in Broker Dealer firms since 1996 Specializing in Broker Dealer firms since 1996 Serving Broker Dealers & Professional Securities Industry Firms 21860 Burbank Blvd, Suite 150 Woodland Hills, CA 91367 Phone: (818) 657-0288 Fax: (818) 657-0299

More information

STATEMENT OF MARTIN J. GRUENBERG CHAIRMAN FEDERAL DEPOSIT INSURANCE CORPORATION VOLCKER RULE IMPLEMENTATION. before the

STATEMENT OF MARTIN J. GRUENBERG CHAIRMAN FEDERAL DEPOSIT INSURANCE CORPORATION VOLCKER RULE IMPLEMENTATION. before the STATEMENT OF MARTIN J. GRUENBERG CHAIRMAN FEDERAL DEPOSIT INSURANCE CORPORATION on VOLCKER RULE IMPLEMENTATION before the COMMITTEE ON FINANCIAL SERVICES UNITED STATES HOUSE OF REPRESENTATIVES February

More information

Morgan Lewis Hedge Fund University Form PF: What You Need to Know

Morgan Lewis Hedge Fund University Form PF: What You Need to Know Morgan Lewis Hedge Fund University Form PF: What You Need to Know July 25, 2012 Please note that any advice contained in this communication is not intended or written to be used, and should not be used,

More information

STATEMENT OF THE INVESTMENT COMPANY INSTITUTE ON THE U.S. COMMODITY FUTURES TRADING COMMISSION S APPROPRIATIONS FOR FISCAL YEAR 2016

STATEMENT OF THE INVESTMENT COMPANY INSTITUTE ON THE U.S. COMMODITY FUTURES TRADING COMMISSION S APPROPRIATIONS FOR FISCAL YEAR 2016 STATEMENT OF THE INVESTMENT COMPANY INSTITUTE ON THE U.S. COMMODITY FUTURES TRADING COMMISSION S APPROPRIATIONS FOR FISCAL YEAR 2016 Subcommittee on Agriculture, Rural Development, Food and Drug Administration,

More information

Department of Labor fiduciary rule

Department of Labor fiduciary rule Department of Labor fiduciary rule Key considerations for broker-dealers and wealth management companies Volume 1 June 2016 kpmg.com About the authors Howard Margolin Howard is a partner in the Financial

More information

Investment Funds in United States: Regulatory Overview

Investment Funds in United States: Regulatory Overview Investment Funds in United States: Regulatory Overview Bryan Chegwidden, James Thomas and Sarah Davidoff, Ropes & Gray LLP This Q&A is part of the PLC multi-jurisdictional guide to investment funds. It

More information

FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS

FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS Primary Business Name: MEYER CAPITAL GROUP CRD Number: 105897 Annual Amendment All Sections Rev.

More information

Investment Adviser Registration for Private Equity Fund Managers

Investment Adviser Registration for Private Equity Fund Managers Investment Adviser Registration for Private Equity Fund Managers The Dodd-Frank Act will require most U.S. private equity fund managers (who were previously exempt from registration) to register as investment

More information

Compliance Review. SEC Requires Hedge Fund Managers to Register as Investment Advisers. Introduction. Rule Amendment

Compliance Review. SEC Requires Hedge Fund Managers to Register as Investment Advisers. Introduction. Rule Amendment Schwab Institutional Volume 14, Issue 3 May 2005 Ongoing Compliance Updates for Investment Advisors Compliance Review IN THIS ISSUE Introduction................................................. 1 Rule

More information

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Date: April 19, 2016 To: Board of Governors From: Staff 1 Subject: Re-proposed joint rules implementing the incentive compensation requirements of the Dodd-Frank

More information

FATCA Update Australian Superannuation Industry

FATCA Update Australian Superannuation Industry May 2014 FATCA Update Australian Superannuation Industry Intergovernmental agreement signed with US, and draft enabling legislation released In welcome news for the Australian superannuation industry and

More information

EMIR Key business impacts for asset managers

EMIR Key business impacts for asset managers External perspective EMIR Key business impacts for asset managers Brian Jackson Partner Audit Deloitte Niamh Geraghty Director Audit Deloitte Patrick Rooney Manager Investment Management Activity Deloitte

More information

FinfraG / EMIR. Your partner to navigate the challenges in investment and risk management. Current Status What you need to know. 23 rd September 2014

FinfraG / EMIR. Your partner to navigate the challenges in investment and risk management. Current Status What you need to know. 23 rd September 2014 Your partner to navigate the challenges in investment and risk management. FinfraG / EMIR ROSENWEG 3 GARTENSTRASSE 19 CH-6340 BAAR/ZUG CH-8002 ZURICH SWITZERLAND SWITZERLAND INFO@INCUBEGROUP.COM INCUBEGROUP.COM

More information

April 12, 2011 BY ELECTRONIC SUBMISSION. Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090

April 12, 2011 BY ELECTRONIC SUBMISSION. Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 BY ELECTRONIC SUBMISSION Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 David A. Stawick Secretary Commodity Futures Trading Commission Three

More information

Key Points. Ref.:EBF_007865E. Brussels, 09 May 2014

Key Points. Ref.:EBF_007865E. Brussels, 09 May 2014 Ref.:EBF_007865E Brussels, 09 May 2014 Launched in 1960, the European Banking Federation is the voice of the European banking sector from the European Union and European Free Trade Association countries.

More information

CFTC Part 4 Exemption Easy Reference Guide. Click on the exemption type for more information on how to file and requirements for each exemption.

CFTC Part 4 Exemption Easy Reference Guide. Click on the exemption type for more information on how to file and requirements for each exemption. Click on the exemption type for more information on how to file and requirements for each exemption. Exemption Type General Relief Who Qualifies Exemptions from Registration 4.13(a)(1) (Pool level for

More information

FSI BRIEFING April 5, 2010 Harmonizing the Regulation & Supervision of Broker-Dealers and Investment Advisers

FSI BRIEFING April 5, 2010 Harmonizing the Regulation & Supervision of Broker-Dealers and Investment Advisers FSI BRIEFING April 5, 2010 Harmonizing the Regulation & Supervision of Broker-Dealers and Investment Advisers Introduction On June 17, 2009, the Obama Administration released its plan for reforming the

More information

MiFID II/MiFIR. Implications for Fund Managers. May 2014. 2014 Deloitte LLP. All rights reserved.

MiFID II/MiFIR. Implications for Fund Managers. May 2014. 2014 Deloitte LLP. All rights reserved. /MiFIR Implications for Fund Managers May 2014 Webinar participants Manmeet Rana Senior Manager Audit Deloitte UK mrana@deloitte.co.uk +44 20 7303 8624 Manmeet Rana is a Senior Manager within Deloitte

More information

SEC Proposes Large Trader Reporting System

SEC Proposes Large Trader Reporting System Financial Institution Advisory and Financial Regulatory Group May 2010 SEC Proposes Large Trader Reporting System I. Overview II. Introduction: Identifying Large Traders On April 14, 2010, the Securities

More information

Dodd-Frank Wall Street Reform and Consumer Protection Act: Implications for Derivatives

Dodd-Frank Wall Street Reform and Consumer Protection Act: Implications for Derivatives DERIVATIVES AND ASSET MANAGEMENT CLIENT PUBLICATION July 2010... Dodd-Frank Wall Street Reform and Consumer Protection Act: Implications for Derivatives... Introduction The Dodd-Frank Wall Street Reform

More information

Annual Compliance Obligations for U.S. SEC-Registered Investment Advisers

Annual Compliance Obligations for U.S. SEC-Registered Investment Advisers Annual Compliance Obligations for U.S. SEC-Registered Investment Advisers January 2014 Below is a summary of several of the annual compliance obligations imposed on investment advisers registered with

More information