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Red Oak Blog

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Saturday, April 21 2012

Quarterly Round-Up- Q1 2012

2012 is moving quickly and the first quarter has drawn to a close. Here’s a round-up of key regulatory news and compliance dates which occurred in Q1 2012, as well as a reminder of compliance considerations we recommend you focus on in the first quarter of the year as you plan ahead to the remainder of 2012.

Q1 2012 Compliance Dates:

We’ve included the following dates solely as a reminder to verify your firm has met the deadlines. We also recommend this is a logical time to review your privacy policies, as well as deliver the privacy policy and Form ADV Part 2 Brochure to your existing clients.

3/1/2012: Massachusetts Privacy Rules Effective.

3/31/2012: Annual ADV Filing Deadline- ALL SEC registered Advisers as of 1/1/2012 required to file an update, regardless of whether they are withdrawing from SEC Registration.

Q1 Regulatory News:

1/4/2012: SEC Office of Compliance Investigations and Examinations (OCIE) issues a Regulatory Alert discussing the use of social media.
http://www.sec.gov/about/offices/ocie/riskalert-socialmedia.pdf

1/19/2012: SEC issues updated FAQs regarding the definition of “Family Office” addressing questions received due to the adoption of Rule 202(a)(11)(G)-1 in 2011.
http://www.sec.gov/divisions/investment/guidance/familyofficefaq.htm

2/2/12: ERISA Section 408(b)(2) Rule Finalized and published.
http://www.dol.gov/ebsa/pdf/2012-02262-PI1.pdf

2/15/12: SEC adopts final rule amendments to 205-3 under the Advisers Act regarding the charging of performance fees.
http://www.sec.gov/news/press/2012/2012-29.htm

2/27/12: SEC Office of Compliance Investigations and Examinations (OCIE) issues Risk Alert- Unauthorized Trading
http://www.sec.gov/news/press/2012/2012-33.htm

During the first quarter, the Red Oak blog covered topics such as the new ERISA rule, getting your compliance house in order, Massachusetts privacy laws, and the revision to the accredited investor definition. If this is your first visit to the blog, Welcome, and we recommend you review the links contained within this post, spend some time reviewing previous posts, and explore the site.