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Investment Fund Law Blog

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U.S. and Global Regulators Ease March 1 Deadline for Swap Variation Margin Compliance

The global compliance deadline for implementation of variation margin requirements for uncleared swap transactions is March 1, 2017.  Unless an exception is available, the rules generally require swap dealers to collect and post variation margin with no credit threshold.  The rules require the parties to enter into new or amended…

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REGISTERED FIRMS: ANNUAL COMPLIANCE OBLIGATIONS – What You Need To Know

The following are some of the important annual compliance obligations investment advisers either registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Adviser”) and commodity pool operators (“CPOs”) or commodity trading advisors (“CTAs”) registered with the Commodity Futures Trading Commission (the “CFTC”) should be…

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Treasury Mandatory Survey Form TIC-SHC Due Soon— Fund Managers Should Assess Foreign Securities Holdings

On December 5, 2016, a Notice of reporting requirements was filed in the Federal Register by the U.S. Department of Treasury informing the public of the Treasury’s mandatory survey, due every 5 years, of ownership of foreign securities by U.S. residents as of December 31, 2016.  All U.S. persons who…

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HFMWEEK AWARDS PILLSBURY INVESTMENT MANAGEMENT PRACTICE FOR SERVICE TO HEDGE FUND STARTUPS

NEW YORK—Pillsbury has been named Best Onshore Law Firm for Hedge Fund Startups by HFMWeek at its HFM U.S. Hedge Fund Services Awards 2016. Partner Ildiko Duckor, who is co-leader of the firm’s Investment Funds & Investment Management practice, accepted the honor at the awards ceremony, which was held at…

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New Law Mandates Disclosure of Alternative Fund Fees By California Public Pensions

To increase the transparency of fees and expenses paid to alternative funds, every California public pension plan must require each alternative fund in which they invest to make various disclosures, and California public pension plans are required to disclose that information during meetings open to the public. Assembly Bill 2833…

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Higher Qualified Client Net Worth Threshold Effective August 15, 2016

3(c)(1) funds should update their offering documents to reflect $2.1 million net worth requirement. Assets under management threshold remains unchanged at $1 million. Only new client relationships entered and new investors admitted in private funds after August 15, 2016 are affected; new contributions by pre-August 15 investors are grandfathered. The…

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Investment Adviser Sanctioned for Inadequate Trading Away Disclosure

On July 14, 2016, the Securities and Exchange Commission (SEC) announced an enforcement action against RiverFront Investment Group, LLC, a registered investment adviser serving as sub-adviser to clients in wrap fee programs established by various sponsors. The enforcement action resulted from RiverFront’s materially inadequate disclosure about changes in its trading practices…

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PILLSBURY BREAKFAST EVENT CONNECTS WOMEN ENTREPRENEURS WITH WOMEN INVESTORS

Pillsbury is hosting Plum Alley Investments, a private-membership on-line platform connecting women investors with businesses run by women entrepreneurs.  The breakfast will feature an intimate conversation about shaping the world by investing in private companies led by women entrepreneurs.  Venue: Pillsbury office, 22nd Floor, Four Embarcadero Center, San Francisco; Wednesday,…

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Rising Hedge Funds Stars Discuss Keys to Success

Pillsbury is hosting a hedge fund startup event with 100 Women in Hedge Funds next Thursday, July 14.  Experts representing two firms named as Institutional Investor’s 2015 Hedge Fund Rising Stars will discuss the essentials to launch and grow an investment firm in today’s environment.  They, along with a tenured…

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SEC wants Registered Advisers to Adopt Written Business Continuity and Transition Plans

In line with the Securities and Exchange Commission’s (SEC) goal to enhance regulatory safeguards in the asset management industry, the SEC yesterday released a proposed new rule and rule amendments under the Investment Advisers Act of 1940. The proposed new rule 206(4)-4 would require SEC-registered investment advisers to adopt and…