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Over the past two weeks, Ross Goffi, from Bovill’s US office, has held briefings in Singapore and Hong Kong discussing recent SEC enforcement trends, high level considerations for non-US fund managers and advisers thinking of soliciting US investors, and fund distribution options for existing fund managers seeking US investment. We found that Asian-based managers who seek to diversify their investor base beyond the region look to the United States as a source of additional investment capital. Along with that investment capital comes the need to understand the SEC’s registration requirements and applicable exemptions.
The well-attended sessions dug into the criteria for fund managers to leverage the exempt reporting adviser (ERA) exemptions under Section 203(l) and 203(m) of the Investment Advisers Act. Also discussed were the ongoing compliance obligations for registered investment advisers (RIAs) and exempt reporting advisers, as well as the SEC advertising rules and no-action relief applicable to firms advertising in the United States. We touched on the process for filing a Form ADV to either report as an ERA or register with the SEC as an RIA and the time expectations for preparing and filing Form ADV.
On the fund distribution side, the sessions talked through the various options available to fund managers including the often misapplied issuer’s exemption and Rule 15a-6 chaperoning.
The sessions were the first of a series of events that Bovill Asia intends to run throughout 2018 focusing on global compliance topics in conjunction with Bovill Americas. We enjoyed meeting the new participants and seeing our existing clients’ interest in Bovill’s expanding global presence. We look forward to hosting more events addressing global compliance topics.
To find out more about any of the topics covered at these events contact Ross Goffi or Rebecca Thorpe below.
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