Search results

To alert investment advisers to changes to be implemented to the Securities and Exchange Commission’s (SEC’s) Form ADV requirements as of October 1, 2017. Form ADV is the SEC’s principal investment adviser registration form.

Explains new public disclosure reporting requirements for investment adviser separately managed accounts (SMA) businesses, assesses the new “umbrella registration rules” that will govern how related advisers are treated by Form ADV, outlines key changes to Form ADV on a provision-by-provision basis, summarizes various other technical additions to Form ADV, and examines new performance reporting record-keeping requirements.

The Form ADV amendments are significant. Investment advisers should be preparing for compliance ahead of the October 2017 compliance date. Information retrieval processes will need to be reviewed and tested against the new disclosure rules. Firms will want to coordinate with their clients to minimize surprises when client data (albeit on an aggregated basis) is made public. Firms that operate under umbrella registrations should check their eligibility against the new rules.

Practical and informative guidance from experienced investment adviser attorneys that consolidates the key provisions of which investment advisers should be aware under new SEC disclosure and recordkeeping requirements.

To explain proposed rules and amendments recently issued by the USA Securities and Exchange Commission (SEC) that would impose more detailed reporting requirements for investment advisers that file Form ADV. A companion article describes the SEC’s proposed registered investment company reporting rules which were issued simultaneously.

Describes the SEC’s reasoning for collecting more detailed data, introduces the proposed separate account reporting requirements for SEC-registered investment advisers, explains proposed amendments to Part 1A of Form ADV, describes a proposed codification of SEC staff positions that provide for so-called “umbrella registrations” by closely related advisory firms, and details two proposed amendments to Advisers Act Rule 204-2, the books and records rule, which would require investment advisers to maintain additional materials related to the calculation and distribution of performance information.

Many questions still remain as to how the final rules will eventually take shape; however, it is evident that investment advisers will be subject to a wider array of reporting requirements. Investment advisors are likely to incur increased costs as a result of the proposed rules and amendments, and production of the reports could necessitate a revamp of their various internal procedures. Also, access to additional and enhanced information will have consequences for investment companies with respect to SEC examinations and enforcement activity.

Investment advisers should understand that detailed new regulatory reporting is coming and, more specifically, separately managed account clients of investment advisers should be made aware of the proposed reporting requirements.

Practical guidance from experienced investment funds lawyer.

To describe some of the challenges that the Securities and Exchange Commission (SEC) will face in requiring that high-frequency traders register as dealers.

This paper provides a brief overview of the dealer-trader distinction, an analytical framework under which some high-frequency traders have avoided registration with the SEC as dealers. It then explains the difficulties the SEC will encounter in bringing high-frequency traders within its regulatory umbrella as dealers. In particular, the paper outlines some of the interpretive challenges the SEC encounter as well as challenges to justifying the economics of any proposal.

While the SEC has yet to formally propose rules in this area, the interpretive vehicle it uses could have repercussions for other market participants that rely on the dealer-trader distinction to avoid having to register as dealers with the SEC.

The paper provides practical insights into the issues the SEC will have to address if it proposes to bring high-frequency traders within its regulatory umbrella as dealers. In addition, it provides a concise overview of the dealer-trader distinction based on statements by the SEC and its staff.

According to Juvenile Justice (Care and Protection) Act, 2015 Act, the registration of Child Care Institutions (CCIs) is compulsory, but the registration process all over the country is being prolonged on the part of the NGOs and other private welfare agencies. Against this background, the researcher intends to study the reasons for reluctance to registration by the CCIs.

The researcher adopted exploratory approach to find the reasons behind the reluctance towards JJ registration. There are 112 children’s homes in Malappuram district, among which 40 institutions did not apply or get JJ Registration. Among these 40, the researcher selected 20 (50%) by simple random sampling. The respondents were one among the institution’s Secretary/President or staff. The method used for extracting data was interview schedule and the collected data were coded and analyzed with the help of the SPSS software.

The CCIs apprehend that their organizational freedom would be limited after registration. Another observation of this study is most of the children’s homes are managed by religious organizations and most of them are worried that registering their institution under this act might adversely affect their religious sentiments. About 60% of the CCIs concern about the financial burden and 85% of them have difficulty to implement the new rules and regulation.

This study covered the 20 children’s Home and all those institutions are run by Muslim religious management, so the situations of child care institutions run by other management (Hindu, Christian, Secular) is not covered by this study.

Addresses the question of whether registration is appropriate for the sales and marketing divisions within companies in the light of Kodak Ltd′s experience of registering the marketing, sales and Customer service department of their Health Sciences Division to Marketing Quality Assurance. Looks at the reasons behind their registration, considers that weekly meetings and newsletters were essential in keeping the process flowing smoothly. Highlights the emphasis placed on Training, especially the audit sessions. Describes how improvements have been measured by benchmarking, using employee and customer Surveys.

The purpose of this paper is to conduct a literature review on framework agreements, an instrument for demand aggregation adopted in the UK, to recommend improvements to the price registration system (SRP), a mechanism often used with reverse online auctions in Brazil envisaged to promote more flexibility in centralized tenders, allowing public bodies to establish contracts when the need arises, based on registered prices.

A literature review was undertaken to analyze the UK framework agreement approach and the Brazilian SRP. In addition, in-depth interviews with civil servants from the Brazilian Ministry of Economy were conducted to examine the SRP.

The experience with framework agreements in the UK reveals at least four ways to improve the Brazilian SRP: i) extending the legal maximum duration of a price registration minute (ARP) ; ii) allowing the registration of additional suppliers in the ARP, instead of only the first lowest bidder; iii) conducting mini-competitions when a contracting authority decides to use the ARP to enter into a contract; and iv) including additional criteria for awarding suppliers, in line with the most economically advantageous tender (MEAT) approach.

The flow of government financial resources into procurement accounted for approximately 16.5% of gross domestic product in Brazil and for an average of 12% in OECD countries in 2017 (OECD, 2019: 135). Public procurement is a strategic function for enabling an efficient public services delivery and infrastructure deployment. It is, therefore, relevant to examine instruments of demand aggregation to improve the outcomes of public procurement.

Framework agreements are currently not used in Brazil. This paper examines the UK experience with framework agreements to propose potential improvements to the Brazilian SRP, a procurement instrument vastly used in the country.

The UK Government has recognised for some time that the UK fund management industry would welcome the availability of a new form of investment vehicle, namely an open‐ended investment company. HM Treasury has recently issued draft regulations relating to the establishment and operation of such companies. This paper compares some other currently available investment vehicles and reviews the proposed legal framework for open‐ended investment companies.

This paper reports the financial aspect of the 2002 National Association of Library and Information Science Educators (NALISE) – Nigerian library and information science educators’ umbrella body. Conference financial difficulties encountered by the hosting department and how these difficulties were tackled are highlighted.

The purpose of this paper is to transform a user‐authentication process for a document delivery and borrowing service into a simplified and unified logon access method consistent with other library services by leveraging a University Lightweight Directory Access Protocol (LDAP).

Data fields were analyzed from the Texas A&M University Libraries' interlibrary loan and document delivery application (ILLiad) to determine the unique information that was critical to maintain account security and historical usage. As an added feature, plans were made and implemented to provide account authentication with another system entity through the use of Shibboleth software.

The campus LDAP proved a popular added feature. Since the implementation of the new authentication and authorization methods, usage of the service has increased even though the number of actual live accounts has decreased. Account security and user affiliation statistics were greatly improved.

More efficient authentication and authorization processes increased the effectiveness of the document delivery service. Use of the LDAP protocol and Shibboleth software enhanced the authentication process for both the library and the user. Eliminating the need for a separate set of credentials for use of the document delivery service reduced the potential for password fatigue.

The creation and implementation of different technologies to further refine migration and systematic processes. A guide to the steps taken to facilitate moving from one authentication method to a more advanced system leveraging Shibboleth and .ASP for quality assurance.