Investment Advisers Regulation - Registration and Reporting - Comment Letter - Katten Muchin Rosenman LLP - January 21, 2011

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Dodd-Frank Timeline, Rules Implementing Amendments to the Investment Advisers Act of 1940, SEC
Final Rule Issue Effective Date Compliance Date
July 19, 2011 September 19, 2011 March 30, 2012

Rules Implementing Amendments to the Investment Advisers Act of 1940
January 21, 2011

Katten Muchin Rosenman LLP submits the comment letter on behalf of APG Asset Management US Inc.

From the comment letter:

"Our comments are directed to the changes in Instruction 5.b.(I) to Form ADV Part 1 that would require, for the first time, that advisers include in their 'regulatory assets under management,' for purposes of determining whether they meet the threshold for required SEC registration:

  1. proprietary assets;
  2. assets managed without the adviser receiving compensation; and
  3. assets of foreign clients, all of which an adviser currently may, but is not required to, include in such determination."

The firm also expresses concerns regarding the following issues:

  • Form ADV's required inclusion of foreign assets; and
  • the "Engaged in Business" requirement in the Advisers Act.


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