Doug Cornelius on compliance for private equity real estate
If you’re going to tell your clients that their money will be invested according to a particular strategy, you need to invest it according to that strategy. If you say that “portfolio management services are based on Modern Portfolio Theory” then you should do so. Should you invest 70% of the client’s assets according to…
The Securities and Exchange Commission is proposing some definitional changes to ease its regulatory flexibility. I didn’t think much of this, putting it into the compliance arcana bucket. That is, until I took a brief look at the changes on the Fact Sheet. The SEC is proposing to increase the definition of a “small” investment…
On September 17, the Securities and Exchange Commission and the Commodity Futures Trading Commission each voted to further extend the date for investment advisers to comply with amendments to Form PF to Oct. 1, 2026. The Form PF amendments were adopted in February 2024 and the original compliance date was March 12, 2025. The compliance…