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.

This document (and any information accessed through links in this document) is provided for information purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking or refraining from any action as a result of the contents of this document.