As an update to the original post (below), we note that the London Stock Exchange announced last week that it is creating its own “dark pool” Pan-European trading facility, to be called Baikal. Baikal was created in partnership with Lehman Brothers. As these pools grow in size and complexity, our compliance concerns, as noted below, [...]
As we head around toward the end of the second quarter — and thus the likely passing of 120 (or 180) days after fiscal year end — hedge fund compliance pros know that it is time to ensure that “custody rule” requirements have been met at their shop. While the SEC’s Rule 206(4)-2 can be [...]
Charlie Rangel (D-NY) has proposed, yet again, that relief to middle-class tax payers (in the form of a reduction of the alternative minimum tax) should be at least partially paid for by the elimination of the favorable tax treatment that fund managers have on the “carried interest” portion of their partnership interests. Under this bill, net income and [...]
For an industry that has cried out for “self-regulation”, and investors who have cried out for “increased transparency”, it is hard to fathom how it is that no EU hedge funds (that’s none, as in zero) have actually signed on to comply with the best practices enumerated in the UK Hedge Fund Working Group Standards report published some [...]
Many registered investment advisers of hedge funds start their annual review of compliance procedures and processes in June. But what exactly are the requirements for this review? Rule 206(4) -7 under the Advisers Act requires registered investment advisers to annually assess the “adequacy and effectiveness” of the compliance program. This review may take place once [...]
Heads up hedge fund registered investment advisers! The SEC’s proposed amendments to Reg S-P (privacy and safe-guarding of personal information) beef it up considerably and, if enacted as proposed, will undoubtedly come at an increased cost to RIA’s. The proposed amendments have several important components related to the development of a much more comprehensive “information security program” [...]
Last week’s indictment by federal prosecutors of an Ernst & Young partner for “tipping” in an insider trading scheme highlights the need for training of hedge fund employees about a very critical, but often over-looked, component of these cases — namely, that a person can be subject to criminal charges for “tipping” regardless of whether [...]
