What is pay to play compliance?
“Pay-to-play” laws regulate political contributions made by persons seeking or holding government contracts. In many cases, these laws also cover contributions made by individuals and entities who are affiliated with government contractors, such as officers, directors, salespersons, and family members.
What is a sub-advisory relationship?
They are the product of relationships formed across the investment management business. They allow an investment manager to contract with other investment managers to offer funds with specific investment objectives. Sub-advisory relationships allow for one alternative in launching new funds for investors.
What is a sub-advisory client?
In a sub-advisory arrangement, you are responsible for contracting directly with the sub-adviser. You are also responsible for ensuring that all disclosure documents (both yours and the sub-adviser’s) and contracts are properly delivered to the client.
What’s the difference between advisor and adviser?
There is no difference between adviser and advisor besides spelling, and both are acceptable for someone who gives advice. Some people, though, feel that advisor is more formal. Advisor tends to be used for people having an official position—for example, an advisor to the president.
Who enforces pay-to-play rules?
SEC Takes Enforcement Actions against Investment Advisers under Pay-to-Play Rule – The SEC announced sanctions against 10 investment advisory firms in January 2017 for violations of Investment Advisers Act Rule 206(4)-5.
What is a covered associate?
Covered Associate means any general partner, managing member or executive officer, or other individual with a similar status or function, any employee who solicits a government entity for the investment adviser and any person who supervises, directly or indirectly, such employee.
Are sub funds legal entities?
The shares/units relating to each sub-fund are backed by different assets, yet they represent a single legal entity.
What is the difference between an AIF and a UCITS?
A UCITS, however, will invest more specifically into liquid financial assets such as bonds, shares and money market instruments. In contrast, an AIF will generally be defined as those funds that do not satisfy the criteria for regulation as UCITS.
What is pay-to-play corruption?
Pay-to-play occurs when investment firms or their employees make campaign contributions to politicians or candidates for office in the hope of receiving business from the municipalities that those political figures represent.
Who has to register with the SEC?
Firms that manage more than $25 million in assets in under management and have at least one managed account need to register with the SEC or the state(s) in which they are located and/or doing business.
What is MSRB Rule G 37?
The Rule prohibits a dealer from engaging in municipal securities business, such as underwriting, advising, or providing other financial services to a municipal issuer, within two years after a contribution to an official of that issuing body.
Is a Qiaif a UCITS?
The QIAIF is an attractive option for hedge funds and funds of hedge funds that may not fit into a UCITS structure. The requirements for liquidity, diversification, restrictions on borrowing and leverage, applicable to a UCITS fund do not apply to a QIAIF.
What are sub funds?
Sub-Funds means the classes of Shares in the Company (and any classes of Shares created hereafter), in respect of each of which a separate investment portfolio of securities is maintained.
How can I get my AIF designation?
In order to become an AIF® Designee, candidates must complete the following requirements:
- Enroll in and complete AIF® Training that satisfies AIF® Training requirements.
- Pass the AIF® Examination.
- Meet the experience requirement (prerequisites)
- Satisfy the Code of Ethics and Conduct Standards.
Is a sub-fund an AIF?
For tax purposes each sub-fund is treated as a separate AIF (see SI 2006/964 Regulation 7 which covers both authorised unit trusts and open-ended investment companies). This means that the umbrella company or trust is not treated as a company for tax purposes.