Blog

SEC Acts Against Private Fund Asset Transfers

On March 15, 2019, the Securities and Exchange Commission (the “SEC”) took cease and desist action against Talimco, LLC (“Talimco”), a private fund manager, and Grant Rogers, its Chief Operating Officer (“Rogers”), finding that Talimco had sold mortgage participations owned by collateralized debt obligations (“CDOs”) that it managed to a fund (the “Fund”) also managed... Read more »

New Provisions of Delaware LLC Law

In July 2018, the Delaware Limited Liability Company (“LLC”) law was amended to allow registered series and division of LLCs.  Delaware LLCs could be divided into series previously, but among other things the series were not considered “registered organizations” for purposes of Title 9 of the Uniform Commercial Code.  LLC series can now be registered by... Read more »

FinCEN Extends and Expands Orders to Identify Beneficial Owners of All-Cash Real Estate Purchases

We reported previously that the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) had issued a Geographic Targeting Orders (GTOs”) originally in July 2016 ordering title insurance companies to identify the actual owners of limited liability companies used in all-cash purchases of high-end real estate ($3 million and greater) in certain cities.  FinCEN has now announced an extension... Read more »

OCIE Issues Risk Alert on Cash Solicitation Rule

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (the “OCIE”) has issued, on October 31, 2018, a Risk Alert concerning compliance with the so-called Cash Solicitation Rule (Rule 206(4)-3 under the Investment Advisers Act of 1940 (the “Advisers Act”)).  The rule requires investment advisers required to be registered under the Advisers Act... Read more »

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