Journal of Investment Compliance: Volume 12 Issue 4

Summary and analysis of Dodd‐Frank rules for investment advisers: registration requirements, exemptions, family offices, performance fee eligibility

Marybeth Sorady, Daren Domina, Wendy Cohen, Fred Santo, Henry Bregstein, Meryl Wiener, Marilyn Okoshi, Jack P. Governale

This paper aims to explain the rules recently adopted by the Securities and Exchange Commission under the provisions of the Dodd‐Frank Wall Street Reform and Consumer Protection…

CFTC issues final rules prohibiting market manipulation

Allison Lurton, William Massey, Robert S. Fleishman

The purpose of this paper is to provide a summary of recent Commodity Futures Trading Commission (CFTC) final rules prohibiting manipulation of commodity markets. The paper…

The Supreme Court's Janus decision: no secondary liability, but many secondary questions

Arthur Delibert, Gregory Wright

The purpose of this paper is to review significant questions raised by the US Supreme Court's June 13, 2011 decision in Janus Capital Group, Inc. v. First Derivative Traders and…

Pay‐to‐play: SEC staff provides new guidance on Advisers Act Rule 206(4)‐5

Edward L. Pittman, Christopher P. Harvey, Michael L. Sherman, Brenden P. Carroll

The purpose of this paper is to explain the SEC staff's web site responses to a series of frequently asked questions concerning SEC Advisers Act Rule 206(4)‐5.

SEC adopts large trader reporting system

Roger D. Blanc, Daniel Schloendorn, Howard L. Kramer, Martin R. Miller, Matthew B. Comstock

The purpose of this article is to inform the various securities market participants about new Exchange Act Rule 13h‐1, its specifics and the requirements it may impose.

Shareholder access litigation and beyond

David B.H. Martin, Keir D. Gumbs

The purpose of this paper is to consider the consequences of the July 22, 2011 decision of the US Court of Appeals for the DC Circuit in the case of Business Roundtable and…

Recent regulatory actions focused on policies and procedures designed to safeguard material, non‐public information

Jason Lane

The purpose of this paper is to review recent regulatory enforcement actions sanctioning firms for failure to safeguard material, non‐public information (MNPI).

Round two of FATCA Guidance: Notice 2011‐34: what's new and what remains on the wish list for non‐US investment funds

Adrienne M. Baker

The purpose of this paper is to highlight areas of particular interest to non‐US investment funds in the second installment of the US Treasury Department's written guidance under…

Russia: insider trading law virtually here

Alexander Anichkin, Yulia Prudnikova

The purpose of this paper is to discuss the enactment and implementation of Russian Federal Law No. 224‐FZ dated 27 July 2010 “On Prevention of Illegitimate Use of Inside…

Selected FINRA notices and disciplinary actions, July‐August 2011

Henry A. Davis

The purpose of this paper is to provide selected Financial Industry Regulatory Authority (FINRA) regulatory notices and disciplinary actions issued in July and August 2011.

Editor column

Henry A. Davis