Get ready for Form ADV, Part 3: Form CRS

Are you ready for Form ADV Part 3? As if the last annual updating amendment filing was not tedious enough with all the additional information related to separately managed accounts, the process will further evolve with the SEC’s proposal for a Form ADV Part 3, also referred to as Form CRS. But don’t worry, it … Continued

New Remedy Coming for SEC’s Custody Rule?

The SEC’s Custody Rule continues to be a common source of confusion and a landmine for noncompliance. Custodial paperwork has caused huge headaches for investment advisers, who are not a party to the agreement and may not even have a copy of the custodial new account paperwork. The issue with existing guidance is that it … Continued

SEC Offers Regulatory Relief to Advisers Affected by Hurricanes

On September 28, 2017, the SEC provided regulatory relief to individuals and entities subject to the ’33 Act, ’34 Act and ’40 Act who were affected by Hurricanes Harvey, Irma or Maria. The relief came in the form of conditional exemptions from certain requirements. The hurricanes, which struck between August and September of 2017, devastated … Continued

Regulation A Plus, FBAR And FATCA Deadlines, And Other Regulatory Filing Dates

The SEC isn’t the only agency investment advisers need to have on their radars. The IRS has extended the reporting deadline for certain FBAR filings, and reporting under the Foreign Account Tax Compliance Act (FATCA) will begin soon, now that the FATCA Portal is open for registration. Firms seeking to be included on the IRS’ … Continued

Latest Content

Past Conference Speaker Inspiration for The Rock’s Next Blockbuster

If you attended Ascendant’s 2016 San Diego conference,  you will no doubt remember our outstanding keynote speaker, Jeff Glasbrenner. Jeff is a below-the-knee amputee who was fresh off becoming the first American amputee ever to scale Mount Everest. In San Diego, he spoke about turning challenges into triumphs, and about succeeding in the face of … Continued

Relief at Last – New Guidance on Inadvertent Custody

The SEC quietly provided additional guidance to the industry about inadvertent custody in supplemental responses to the Custody Rule FAQs. In Question II.11 and II.12, the SEC stated that it would not recommend enforcement against an adviser that does not have a copy of a client’s custodial agreement, and does not know or have reason … Continued

Cayman Islands Update AML Regulations for Private Equity

The Cayman Islands has further bolstered its anti-money laundering (“AML”) and countering of terrorist financing (“CTF”) rules. The new AML/CTF rules become effective on May 31, 2018 and will affect, among others, unregulated investment entities—such as private equity firms—domiciled in the Cayman Islands. The deadline to appoint AML officers, however, is September 30, 2018 for … Continued

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