FinCEN Sets Foundation for Real Estate Anti-Money Laundering Regulations

The Financial Crimes Enforcement Network (FinCEN) has gotten more active in fighting money laundering. While the last administration mostly focused on putting parties on the sanctions list, the current administration is looking to expand regulatory requirements. One of the several initiative recently launched is targeted at real estate. On December 8, FinCEN announced an Advance Notice … Read more »

FINRA Extends Parking Period from Two Years to Five Years

Registered Representatives with a broker-dealer presently have two years from their date of leaving a firm to re-register with another firm. Otherwise their qualifications, and especially their passed examinations, would lapse. Reps would sometimes try to “park” their registration at a firm to avoid having to re-take examinations. Nobody wants to re-take those exams. FINRA … Read more »

SEC Chairman Gensler Talks About Private Funds

Last week, Securities and Exchange Commission Chair Gary Gensler, made a speech at the Institutional Limited Partners Association Summit. The topic? (You can guess by the title.) Private Funds. In particular, potential new regulatory requirements around private fund. I think it’s time we take stock of the rapid growth and changes in this field, as … Read more »

The Division of Examinations Is Not Happy with your Fee Calculation

The SEC’s Division of Examination ran a sweep of exams focused on advisory fees, predominantly those charged to retail clients. Not bothering with any clever names, it was simply the Advisory Fees Initiative. The Division placed 130 examination into the Initiative. The results are in a recent Risk Alert: Division of Examinations Observations: Investment Advisers’ … Read more »