Alexandra Poe

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The SEC Office of Compliance Inspections and Examinations (“OCIE” or the “Staff”) released its 2016 Exam Priorities recently, as applicable to examined registrants other than national securities exchanges.   Exam Priorities are always a reflection of current trends and news and, in recent years, also reflected the SEC’s expanded capabilities for monitoring market activity through data analytics.   The three key themes and many of the individual focus items for 2016 are much the same as last…
Very interesting report from deal advisor Freeman & Co this morning, reporting 50 asset manager acquisitions globally in 1H15. The advisory firm notes an increase in mid-size deals relative to last year.  “Deals involving firms with $1-10 billion in AUM, experienced a notable increase during 1H 2015 with 30 deals announced year-to-date, a 20% increase from 25 in 1H 2014.”  See attached news release from Freeman & Co. LLC for further trend analysis and let…
The SEC Office of Compliance Inspections and Examinations (“OCIE” or the “Staff”) recently released its 2015 Exam Priorities. OCIE examines all types of SEC registrants, including investment advisers, broker-dealers, investment companies, municipal advisors and transfer agents. Each January, the release of the OCIE Exam Priorities provides a useful guide and reminder to registrants in connection with their individual compliance program and risk management reviews for the year ahead. Exam Priorities are always a reflection of…
This post was also written by Paul Bond, Keri Bruce, and Frederick Lah. Last week, the SEC proposed amendments (PDF) to Rule 506 of Reg D to lift a long-standing ban on advertising for hedge funds and certain other investments in the United States. Over the course of the next few weeks, Reed Smith will be releasing a series of blog posts about the various implications this proposed rule may have if it goes into…
Having been the first advocate to the Investment Company Institute’s SEC Rules Committee to promote the recognition of domestic partners for purposes of federal securities law compliance circa 1998 (with vociferous counterpoint from other Committee members), I am delighted to report the following. In adopting final adviser registration rules under Dodd Frank in 2011, pursuant to the comments of the American Bar Association, the SEC now recognizes “spousal equivalents” defined as “cohabitants occupying a relationship…
The SEC adopted final whistleblower rules (PDF) on May 25, 2011. The crux of the news here is that SEC decided not to require whistleblowers to report suspected law violations internally before reporting them to the SEC. Although the SEC staff knows, better than most, the wide variety of things that motivate employees to inform on their employers (and on one another), the desire to attract a good flow of “quality” reports to the SEC…
This post was written by Sandra Poe and Alicia Powell. In the Private Fund Investment Advisers Registration Act of 2010, Congress adopted changes to the Investment Advisers Act of 1940 that greatly increase the chances that managers of hedge funds or private equity funds will now have to register as investment advisers.  Advisers who are required to register will have about a year to do so — until July 21, 2011.  Widely covered in the news as “hedge fund registration”…