Investment Management Law: Recent Comments

Comment on NYS Attorney General Says that Law Firm Introductions Required BD Registration

2010-10-14T14:54:56Z

The NYS AG made clear that the compensation was not what triggered registration. This was probably because the NYS AG had no jurisdiction over the CalPERS transaction. With respect to all the New York activity over which the NYS AG had jurisdiction, the law firm received no compensation and was not successful in soliciting investments. I think this is a significant expansion of the Martin Act.

Comment on NYS Attorney General Says that Law Firm Introductions Required BD Registration

2010-10-14T13:00:22Z

I think you guys were reading too fast. This is from the AG’s press release:

Manatt received fees for successfully placing one investment with the California Public Employees’ Retirement System (“CalPERS”). Its other efforts failed.
* * *
The investigation by the Attorney General’s office found the following instances in which Manatt sought to help firms obtain investments from public pension funds without a securities license:
• In 2003, in partnership with California-based lobbyist Platinum Advisors, Manatt helped to place a $25 million investment by CalPERS in Levine Leichtman Capital Partners Fund III, for which Manatt and Platinum each received $187,500

I’m guessing you read the following without reading the whole thing: “Other than the CalPERS investment in 2003, no investments resulted from Manatt’s efforts and Manatt did not receive compensation.”

You should put out a correction.

Comment on Donohue Says that BD Registration is Required for Private Fund Intermediaries

2010-09-09T15:35:23Z

Other Internet users should advocate the content of this resource

Comment on FINRA Proposes Simplified Rule Governing Personal Securities Transactions

2010-08-26T18:59:59Z

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Comment on NY AG Sues Adviser Alleged to Have Suspected Madoff Fraud Back in 1997

2010-08-26T18:42:19Z

That was a terrific article. I stumbled across this piece and found it very effective.

Comment on SEC Charges Private Equity Execs with Securities Fraud

2010-08-26T17:30:22Z

That was an amazing piece of writing. I stumbled across your piece of writing and thought it very helpful.

Comment on FINRA Proposes New Compliance Exam Along with Other Changes to Registration/Qualification Requirements

2010-08-23T06:46:56Z

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Comment on Ketchum Wants Firms to Segregate Advisory Activities

2010-07-22T06:32:37Z

An excellent presentation. Clear. Practical. Insightful. Shows a depth of experience. Thank you. I learned a great deal.

Comment on Ketchum Wants Firms to Segregate Advisory Activities

2010-06-23T23:53:57Z

I think you have given a great guideline out there.

Comment on FINRA Expands Regulatory Jurisdiction to NYSE

2010-05-05T14:08:40Z

The headline should read, "NYSE completes takeover of FINRA."