Wednesday, November 4, 2009
SEC Registration Bill Advances, But Now What ? Practical Advice on How to Prepare
Following last week's House Committee on Financial Services clearing a bill that would require most alternative investment fund managers to register with the SEC you may wish to read an overview of how and what to do to prepare your Firm for Registration.
In a column late this summer Thomson's BuyoutsNews prodded buyout shops to take a stronger stand against proposed legislation requiring them to register as investments advisers with the SEC. That article was titled "Will Industry Accept SEC Registration Without A Fight?" In it you can read how many firms may be tempted to tap a CFO or other partner as chief compliance officer, rather than hiring a full-time CCO. But that could prove short-sighted, given the complexity of the job, and the fact the SEC tends to stop by for examinations every two to four years. "One of the ways to get into big trouble is to adopt policies and procedures off-the-shelf and not to follow them," cautioned a Partner at Ropes & Gray.
Registering as investment advisers, following the compliance policies and procedures, dealing with regular inspections-all these activities absorb yet more time and energy. These are among the main areas that firms would likely need to change how they do things and you can read below on what and how to do it. Read more.
To see all DRAFTS of the Financial Regulatory Reform now being considered by the House Financial Services Committee click here Click here to write to your Representative about issues relating to the Financial Services Committee.
Posted by Stuart Rosenthal