On May 22, 2020, the Small Business Administration (SBA) issued its interim final rule on loan forgiveness. The rule describes, in a question-and-answer format, the mechanics of applying for and receiving loan forgiveness under the Paycheck Protection Program. In “SBA Issues Long-Awaited Paycheck Protection Program Forgiveness Regulations,” colleagues Jenny Y.…
Both the House and Senate have passed a bipartisan bill to modify elements of the PPP established by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The legislation, intended to provide a “quick fix” to obstacles faced by small businesses seeking relief under the forgivable loan program, was…
We urge our clients to consult Pillsbury’s comprehensive COVID-19 Resource Center for information regarding Responding to a Global Crisis, Business Interruption, Cybersecurity, Employer Concerns and other general matters related to the COVID-19 pandemic. We also recommend the following specific measures to mitigate risks of business interruption and regulatory noncompliance resulting…
Registered and Exempt Reporting Firms: The deadline for the annual update of Form ADV is approaching. We have previously notified you regarding filing obligations that were due between January 1 and March 1. Below is a recommended compliance and filing deadline table addressing registered firms’ obligations for the remainder of the…
In response to the coronavirus pandemic, see the Pillsbury articles and webinar regarding our recommendations. If you have not already, at this point you should: Review and/or activate your business continuity plan Review your vendor relationships and assess any stressors Shore up cybersecurity protections and be vigilant regarding heightened risks…
The California Consumer Privacy Act (CCPA), a broad statute which imposes new data privacy obligations on certain companies that do business in California, will become effective on January 1, 2020. Fund managers and other investment advisers (“Advisers”) and certain of their affiliates that are currently subject to data privacy laws…
Recommendations for employers before new law goes into effect on January 1, 2020 TAKEAWAYS On September 18, 2019, California Governor Gavin Newsom signed into law a bill making it risky for employers (regardless of size) to classify many types of workers as independent contractors. As employees, these workers will be…
This is a reminder about the upcoming annual compliance deadlines that may or may not apply to you. Please click HERE to open a summary chart of the filing deadlines. Please feel free to contact us if you have questions or need assistance with any of these filings. Sincerely, Pillsbury IFIM…
In a press release issued by the Securities and Exchange Commission on December 20, 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2019 Examination Priorities. This year’s examination priorities, although not exhaustive, are divided into 6 categories: Compliance and risk at registrants responsible for critical market…
This is a reminder that the 2019 IARD account renewal obligation for investment advisers (including exempt reporting advisers) starts this November. An investment adviser must ensure that its IARD account is adequately funded to cover payment of all applicable registration renewal fees and notice filing fees. Key Dates in the…