Publications

Update on Registration, Compliance and Examinations

Fall 2007
Marc E. Elovitz
Investment Management Developments - Fall 2007

On July 24, 2007, the Securities & Exchange Commission’s (“SEC”) Division of Investment Management and Office of Compliance Inspections and Examinations came out with a guide for recently registered investment advisers. (According to the SEC, approximately 30% of all registered investment advisers became registered since January 2005.) The guide identifies many of the important compliance areas, including fiduciary duties, Form ADV and other filings, code of ethics, best execution, and books-and-records requirements. Because it provides a general overview of these areas, the guide will likely be the starting point of the analysis of most issues.