Investment Management Law: Recent Comments

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

Todd Cipperman — Thu, 14 Oct 2010 14:54:56 GMT

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

Mark Sides — Thu, 14 Oct 2010 13:00:22 GMT

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

seo consulting experts — Thu, 09 Sep 2010 15:35:23 GMT

Other Internet users should advocate the content of this resource

Comment on FINRA Proposes Simplified Rule Governing Personal Securities Transactions

Binaural Beats — Thu, 26 Aug 2010 18:59:59 GMT

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

Binaural Beats — Thu, 26 Aug 2010 18:42:19 GMT

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

Binaural Beats — Thu, 26 Aug 2010 17:30:22 GMT

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

Slama Pofer — Mon, 23 Aug 2010 06:46:56 GMT

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Comment on Ketchum Wants Firms to Segregate Advisory Activities

company financial analysis — Thu, 22 Jul 2010 06:32:37 GMT

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

adviser investment management — Wed, 23 Jun 2010 23:53:57 GMT

I think you have given a great guideline out there.

Comment on FINRA Expands Regulatory Jurisdiction to NYSE

Bill Alsover — Wed, 05 May 2010 14:08:40 GMT

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