Keywords: Participating affiliate
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Journal Articles

A review of the SEC Participating Affiliate No-Action Letters’ relief from Investment Advisers Act of 1940 registration for foreign investment advisers

Wendy E. Cohen, David Y. Dickstein, Christian B. Hennion, Richard D. Marshall, Allison C. Yacker, Lance A. Zinman
Journal: Journal of Investment Compliance
Journal of Investment Compliance (2017) 18 (4): 22–28.
https://doi.org/10.1108/JOIC-08-2017-0057
Published: 06 November 2017
...Wendy E. Cohen; David Y. Dickstein; Christian B. Hennion; Richard D. Marshall; Allison C. Yacker; Lance A. Zinman Purpose To explain the US Securities and Exchange Commission (the “SEC”) staff’s (the “Staff”) participating affiliate exemption from investment adviser registration for foreign...
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Journal Articles

SEC publishes important guidance on the Custody Rule, participating affiliate arrangements, robo-advisers, Form PF and certain compliance topics

Joyce E. Larson, Kara J. Brown, Ivet A. Bell
Journal: Journal of Investment Compliance
Journal of Investment Compliance (2017) 18 (3): 34–40.
https://doi.org/10.1108/JOIC-06-2017-0036
Published: 04 September 2017
.../methodology/approach Summarizes recent guidance regarding issues related to several challenging Advisers Act requirements, including inadvertent custody and client account transfers under Advisers Act Rule 206(4)-2, the use of participating affiliate arrangements pursuant to the “Unibanco” no-action letters...
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