Comments Show Divergent Responses to Proposed SEC Advertising Rules

October 30, 2012 § 2 Comments

After multiple delays, the SEC finally proposed rule changes to permit advertising under Rule 506 offerings and invited comments from the public. To date, the SEC has received over 150 of comments which show a wide range of responses to the proposed rule. Given the number and range of responses, we anticipate slow going for adoption of final rules. « Read the rest of this entry »

SEC Launches National Exam Program for Newly-Registered Fund Advisers

October 14, 2012 § Leave a comment

The SEC’s Office of Compliance Inspections and Examinations (OCIE) recently announced creation of the National Exam Program (NEP), a two-year initiative to conduct risk-based examinations of advisers to private funds that recently registered with the SEC (i.e., registered after Dodd-Frank). The so-called “Presence Exams” initiative will take place over three phases: engagement, examination and reporting.  « Read the rest of this entry »

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