Searching Content by Catherine M. Anderson from Foley Hoag LLP ordered by Published Date Descending.
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Form SHL: Report of Foreign Residents' Holdings of U.S. Securities Due August 30, 2019
Investment advisers, hedge and private fund managers and U.S.-resident entities should review whether they have any filing obligations under Treasury International Capital ("TIC")
United States
19 Aug 2019
SEC Brings First Enforcement Action For Identity Theft Red Flags Rule Violations
On September 26, in the Securities and Exchange Commission's ("SEC") first enforcement action for violations of Regulation S-ID (the "Identity Theft Red Flags Rule"), Voya Financial Advisors Inc.
United States
17 Oct 2018
Cayman AML Officers – Further Clarification From CIMA Regarding Deadlines
Further to our recent Foley Adviser, the Cayman Islands Monetary Authority (CIMA) has clarified today that the deadline for the appointment ...
Cayman Islands
28 Sep 2018
Cayman AML Officer Appointment Deadline Extended For Existing Funds To December 31, 2018
On September 24, 2018, the Cayman Islands Monetary Authority (CIMA) announced the deadline for the appointment by a regulated or unregulated fund of an Anti-Money Laundering Compliance Officer ...
Cayman Islands
28 Sep 2018
Reminder: Appointment Of AML Officers For Cayman Funds Due By September 30, 2018
Advisers that manage any Cayman Islands regulated or unregulated funds, investment entities including hedge funds, private equity funds or any other "financial services business" are reminded that September 30, 2018...
United States
16 Aug 2018
SEC Fines Delinquent Form PF Filers $75,000
Last week, the Securities and Exchange Commission (SEC) announced settlements with 13 SEC registered investment advisers that had failed to file Form PF over multiple year periods.
United States
8 Jun 2018
GDPR: Q&A For Investment Advisers And Private Fund Managers
As many of you may already be aware, the European GDPR goes into effect during May 2018. Below are some frequently asked questions and answers about GDPR as a short guide to assist investment advisers ...
European Union
13 Apr 2018
BE-12 Benchmark Survey Of Foreign Direct Investment In The U.S. Due May 31, 2018
Companies should take note that the U.S. Bureau of Economic Analysis (BEA) is conducting its 5 year benchmark survey relating to cross-border investment: BE-12.
United States
9 Mar 2018
TIC Form SHC 5-Year Benchmark Survey Of U.S. Ownership Of Foreign Securities Due March 3, 2017
Investment advisers are reminded to review their filing obligations under the TIC Form SHC as reporting on this 5-year benchmark survey is due on March 3, 2017.
United States
1 Mar 2017
Sharing Consumer Health Information? Look To HIPAA And The FTC Act
The HIPAA Privacy Rule applies to HIPAA covered entities— a health plan, most health care providers, or a health care clearinghouse.
United States
2 Nov 2016
SEC Proposes Rule Requiring Investment Advisers To Adopt Business Continuity And Transition Plans
The proposed rule would amend current Rule 204-2 under the Investment Advisers Act of 1940 (the "Advisers Act") and require certain recordkeeping of such plans.
United States
18 Jul 2016
Amendment To The Annual Privacy Notice Delivery Obligations Of Financial Institutions Under The Gramm-Leach-Bliley Act Contained In The FAST Act
On December 4, 2015, President Obama signed the Fixing America's Surface Transportation Act (the ‘‘FAST Act'') into law.
United States
12 Jan 2016
CFTC Approves NFA Interpretive Notice On Information Systems Security Programs, Including Cybersecurity Guidance
Members should review their ISSPs at least annually and should make regular adjustments as needed.
United States
4 Nov 2015
Impact Of New European AIFMD Regulation On SBICs
As a threshold matter, the main provisions of the AIFMD only apply to managers that, in aggregate, have EUR100 million (about USD 112 million at today's exchange rates) or more of assets under management in all of their funds.
United States
20 Oct 2015
Bureau Of Economic Analysis (BEA) Issues New Form BE-180 For U.S. Financial Services Providers Including Investment Advisers
Now that the dust has settled a little on the BE-10 benchmark survey responses, U.S. financial service providers, including investment advisers...
United States
7 Oct 2015
The SEC Charges Investment Adviser With Violating Regulation S-P By Failing To Adopt Cybersecurity Policies And Procedures
In recent years, the SEC has been focused on cybersecurity. It has issued risk alerts, conducted examinations and provided guidance about what the agency sees as widespread weaknesses in many policies and procedures to protect against cyberthreats.
United States
1 Oct 2015
SEC Issues Risk Alert Announcing Second Round Of Examinations Of Registered Investment Advisers And Broker-Dealers
From our colleagues Catherine Anderson and Lauren Tran, we present this update on OCIE's 2015 Cybersecurity Examination Initiative: Second Round of Cybersecurity Examinations to Begin
United States
29 Sep 2015
OCIE's 2015 Cybersecurity Examination Initiative
On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing a second round of examinations of registered investment advisers and broker-dealers under its cybersecurity examination initiative.
United States
28 Sep 2015
Bureau Of Economic Analysis (BEA) Form BE-10 August 31, 2015 Deadline Approaching
For those clients that received extensions on the filing deadline for their BE-10 surveys, they are reminded that the August 31, 2015 deadline is approaching.
United States
27 Aug 2015
AIFMD: ESMA Recommends The First Wave Of Non-EU Countries To Obtain A Europe-Wide Marketing Passport
The Advice assessed six countries (Guernsey, Hong Kong, Jersey, Singapore, Switzerland and the United States) of the 22 non-EU countries expected to be assessed for the purposes of the extension of the AIFMD passport.
7 Aug 2015
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