Effective October 17, 2011, certain personnel involved in the back office operations of a broker-dealer must pass a FINRA qualification examination, and subsequently register as an Operations Professional. The Rule further requires senior management having direct responsibility over such personnel to also register. Operations Professionals can be considered: (i) senior management with a direct responsibility over back office functions; (ii) […]
Via Sadis & Goldberg – All hedge fund managers that invest in “new issues” will need to update their funds’ Subscription Documents for new investors and recertify their existing investors in order to continue to be eligible to purchase “new issues” under the “Spinning Prohibition Rules” adopted by the Financial Industry Regulatory Authority, Inc. (“FINRA”). The Spinning Prohibition Rules generally […]
Sadis & Goldberg: Municipal Advisers Registration Alert
Municipal Advisers* are to register with the SEC by December 31, 2011, according to hedge fund law firm Sadis & Goldberg. “Municipal Advisers” who missed the filing deadline last year may also be subject to enforcement action for acting as an unregistered “Municipal Adviser.” *The Dodd-Frank Act defines a “Municipal Adviser” as any person who provides advice to or on behalf […]