Seward & Kissel briefing: Annual regulatory reminders
Seward & Kissel publishes its 2018 annual regulatory reminders memorandum.
On 09 February 2018, Seward & Kissel published a memorandum, “Annual regulatory reminders”, highlighting requirements applicable to the following advisers.
All investment advisers (including those not registered with the Securities and Exchange Commission (SEC)) should review Section 1. Sections 2 - 5 should be reviewed by advisers where applicable.
1. All advisers
- Securities Exchange Act of 1934 Filings
- Privacy Notice
- New Issue Eligibility
- Contractual Obligations
- ERISA
- Private Offering Exemption Filings
- Rule 506(d) under Regulation D of the Securities Act, and
- TIC and BEA Reporting Requirements
2. SEC registered advisers and exempt reporting advisers
- Form ADV Annual Amendment and Delivery, and
- State Filings
3. SEC registered advisers
- Compliance Policies and Procedures
- Audited Financial Statements and Surprise Exams, and
- Form PF
4. Advisers that trade futures, commodities, certain swaps and other commodity interests
- Commodity Pool Operators, and
- Commodity Trading Advisors
5. Private equity and venture capital fund advisers
For more information contact an attorney at Seward & Kissel or Richard Perry.
