I never find it boring to review the investment adviser exemptions for private fund managers.  Apparently, I am not the only one since this is a question we frequently field.

Initially, private fund manager investment advisers, who are primarily regulated by the SEC, that is, large adviser firms with $100 million or more in assets

On December 17, 2020, SEC created the Division of Examinations by renaming the now defunct, Office of Compliance Inspections and Examinations, making it the SEC’s 6th Division joining Enforcement, Corporation Finance, Trading and Markets, Investment Management, and Economic and Risk Analysis (DERA).

A couple of months later, the new Examinations  Division  announced its 2021 examination

Fox Rothschild’s Securities Industry Group is pleased to announce its publication of an interactive Survey of State Blue Sky Filing Requirements.   SI Group members, A. Binford Minter and Jennifer M. Vinciguerra, were instrumental in developing the site.  We encourage all of our readers to visit the site and see what it may be able to

We were recently reminded of how difficult it is to re-register for a position in the securities industry after being barred.  See https://www.sec.gov/litigation/admin/2021/ia-5682.pdf.

On February 9, 2021, the United States Securities and Exchange Commission refused to let a former investment adviser re-register, claiming that the barred adviser had not demonstrated “extraordinary circumstances” to merit re-entry

In what has become a yearly occurrence, FINRA has notified its member firms about its intent regarding the member firms’ compliance programs.  See https://www.finra.org/rules-guidance/guidance/reports/2021-finras-examination-and-risk-monitoring-program.

This year, FINRA combined its Report on Examination Findings and Observations (an analysis of prior examination results) and the Risk Monitoring and Examination Program Priorities Letter (planned areas of review) into

In a stark 3-2 vote along political lines, the SEC announced today that it was proposing new rules relating to finders.  Essentially, if the proposed rules are, ultimately, approved, the SEC will sharply change the position it has maintained for over 8 decades, allowing unregistered finders to sell securities to the investing public while receiving

Recently, the Office of Compliance Inspections and Examinations (“OCIE”) released an alert to broker-dealers and registered investment advisers regarding the risks associated with credential stuffing.  See https://www.sec.gov/files/Risk%20Alert%20-%20Credential%20Compromise.pdf.

Credential stuffing is an automated attack on web-based user accounts and direct network login account credentials. Cyber attackers obtain lists of usernames, email addresses, and corresponding passwords from

Money service businesses received a reprieve last week that will make cryptocurrency firms very happy since they will be able to more easily expand across the United States. The Conference of State Bank Supervisors (“CSBS”) – 48 state regulators – agreed on a regulatory system for money services’ businesses, including a single set of supervisory