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Entries from October 2007

Charlie’s Tax Proposals (2008 update)

Posted under Tax Matters on October 30th, 2007 by Aileen Doherty0 comments

In October, 2007, Rep. Charlie Rangel, the Democratic chairman of the House Ways and Means Committee set forth a proposal that would be a “massive overhaul of the American tax system with serious implications for the private equity and hedge fund industries.” Some of the modifications that would impact the hedge fund and private equity [...]

SAC, HR and what might have been…

Posted under Risk Management on October 23rd, 2007 by Aileen Doherty0 comments

By now you have all probably heard about the junior trader at SAC Capital, his discrimination and harassment lawsuit against the company, and the junior trader’s boss. Andrew Tong, the employee, alleges that his boss Ping Jiang forced him to take estrogen hormone pills and wear a dress to work for the apparent purpose of [...]

Tinker, Tailor…

Posted under Risk Management on October 16th, 2007 by Aileen Doherty0 comments

Recently the SEC issued an administrative proceeding against an investment adviser and its Chief Compliance Officer for adopting and implementing a pre-packaged compliance manual that failed to undertake adequate efforts to identify the risk factors or specific conflicts that may have been applicable to its operation as a pension consultant. While pre-packaged compliance manuals get [...]

SEC/NYAG Focus on NYS Pension Fund

Posted under Risk Management on October 14th, 2007 by Aileen Doherty0 comments

The SEC is now also joining the fury of investigative firepower being leveled at the New York State Common Retirement Fund during the tenure of former Comptroller Alan Hevasi. This on the heels of security law investigations originating back in January by both the NYS Attorney General Andrew Cuomo and Albany County district attorney P. [...]

SEC provides additional clarification for Custody Rule

Posted under Compliance Program,SEC on October 8th, 2007 by Aileen Doherty0 comments

In a September 30, 2007 no-action letter addressed to the Investment Adviser’s Association, the SEC carved out two additional safe harbors  for investment advisers who ‘inadvertently” receive client assets from third parties, specifically for:  -  tax refunds  - class action settlements, and – stock certificates or dividendsThe SEC provided relief of enforcement of Rule 206(4) of [...]