Doug Cornelius on compliance for private equity real estate
The Securities and Exchange Commission has been skeptical of registered investment advisers using advertisements. The default position is always that it’s likely to be fraudulent, deceptive or manipulative and therefore a violation of Section 206 of the Investment Advisers Act. The level of skepticism has been even higher for performance advertisements and even higher for performance … Read more »
These are my notes from an ACA Compliance Webcast on this subject. I’m sure you can find a replay on the ACA website. There were three great presenters: Alicia Hyde, Partner, ACA Performance Services Mike Sonnenburg, CIPM, Managing Director, ACA Performance Services Kim Daly, Managing Director, ACA Compliance Group Definitions The first topic was what … Read more »