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Oct 22, 2024 | 
natlawreview.com | Jennifer L. Klass
In order to discourage investment advisers, broker-dealers and investment companies from engaging in any “tricks,” the SEC Division of Examinations has published a treat, in the form of its 2025 Examination Priorities (the Priorities). This publication, an annual event since 2013, provides market participants with insight into what the Division of Examinations will focus on in the coming fiscal year. All told, the 2025 version of the Examination Priorities has not changed very much from 2024.
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Sep 4, 2024 | 
mondaq.com | Jennifer L. Klass |Richard Kerr
On 28 August 2024, the Financial Crimes Enforcement Network
(FinCEN) finalized regulations that add certain
investment advisers (Covered Advisers) to the definition of a
"financial institution" under the Bank Secrecy Act
thereby requiring Covered Advisers to, among other things,
establish anti-money laundering (AML) and counter-terrorist
financing (CFT) programs and file Suspicious Activity Reports with
FinCEN. The effective date of the new rules is January 1, 2026.
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Aug 30, 2024 | 
natlawreview.com | James Plunkett |Geoff Schweller |Richard Kerr |Jennifer L. Klass
Skip to main content August 30, 2024 Volume XIV, Number 243 Legal Analysis. Expertly Written. Quickly Found. Trending News United States | Legacy Online PERM System Will Permanently Shut Down Dec.
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Aug 5, 2024 | 
law360.com | Cheryl Isaac |Jennifer L. Klass |Matthew Rogers
By Cheryl Isaac, Jennifer Klass and Matthew Rogers (August 5, 2024, 6:00 PM EDT) -- The emergence of generative artificial intelligence affects every sector of the financial services industry, including asset managers.... Law360 is on it, so you are, too. A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.
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Jun 25, 2024 | 
natlawreview.com | Jennifer L. Klass
On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the USA Patriot Act1 (Proposed CIP Rule), which would require SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish written customer identification programs (CIP).
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Apr 18, 2024 | 
mondaq.com | Jennifer L. Klass |Matthew Rogers |Bradley D. Bostwick
On 27 March 2024, the US Securities and Exchange Commission
(SEC) adopted amendments (the Amendments) to Rule 203A-2(e) under the
Investment Advisers Act of 1940 (Advisers Act). Rule 203A-2(e) is
commonly known as the "Internet Adviser Exemption."
Originally adopted in 2002, advisers relying on the Internet
Adviser Exemption are permitted to register with the SEC, even if
they do not have enough assets under management or otherwise
qualify for federal registration.
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Apr 17, 2024 | 
jdsupra.com | Bradley D. Bostwick |Jennifer L. Klass |Matthew Rogers
Brief OverviewOn 27 March 2024, the US Securities and Exchange Commission (SEC) adopted amendments (the Amendments) to Rule 203A-2(e) under the Investment Advisers Act of 1940 (Advisers Act). Rule 203A-2(e) is commonly known as the “Internet Adviser Exemption.” Originally adopted in 2002, advisers relying on the Internet Adviser Exemption are permitted to register with the SEC, even if they do not have enough assets under management or otherwise qualify for federal registration.
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Apr 15, 2024 | 
lexology.com | Jennifer L. Klass |Matthew Rogers |Bradley D. Bostwick
Brief OverviewOn 27 March 2024, the US Securities and Exchange Commission (SEC) adopted amendments (the Amendments) to Rule 203A-2(e) under the Investment Advisers Act of 1940 (Advisers Act). Rule 203A-2(e) is commonly known as the “Internet Adviser Exemption.” Originally adopted in 2002, advisers relying on the Internet Adviser Exemption are permitted to register with the SEC, even if they do not have enough assets under management or otherwise qualify for federal registration.
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Apr 3, 2024 | 
mondaq.com | Jennifer L. Klass |Matthew Rogers |Bradley D. Bostwick
On 27 March 2024, the US Securities and Exchange Commission
(SEC) adopted amendments (the Amendments) to Rule 203A-2(e)
under the Investment Advisers Act of 1940, known as the
"Internet Adviser Exemption." The Internet Adviser
Exemption allows certain advisers that provide investment advice
through an interactive website (Internet Advisers) to register with
the SEC, even if they do not have enough assets under management to
otherwise qualify for federal registration.
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Mar 28, 2024 | 
natlawreview.com | Jennifer L. Klass
On 27 March 2024, the U.S. Securities and Exchange Commission (SEC) adopted amendments (the Amendments) to Rule 203A-2(e) under the Investment Advisers Act of 1940, known as the “Internet Adviser Exemption.” The Internet Adviser Exemption allows certain advisers that provide investment advice through an interactive website (Internet Advisers) to register with the SEC, even if they do not have enough assets under management to otherwise qualify for federal registration.
