Due Diligence

Dodd-Frank Implementation Calendar, For Stuff Affecting Oversight of B/ds & Investment Advisers

As culled from the SEC website:

January - March 2011 (planned)

§§404 and 406: Propose (jointly with the CFTC for dual-registered investment advisers) rules to implement reporting obligations on investment advisers related to the assessment of systemic risk

§418: Propose rules to adjust the threshold for "qualified client"

§913: Report to Congress regarding the study of the obligations of brokers, dealers and investment advisers

§914: Report to Congress regarding the need for enhanced resources for investment adviser examinations and enforcement

§919B: Complete study of ways to improve investor access to information about investment advisers and broker-dealers

§956: Propose rules (jointly with other regulators) regarding disclosure of, and prohibitions of certain, executive compensation structures and arrangements

§922: Adopt rules to implement a Whistleblower Incentives & Protection Program

The rest of the year, after the jump.

April - July, 2011 (planned)

§§404 and 406: Adopt rules (jointly with the CFTC for dual-registered investment advisers) to implement reporting obligations on investment advisers related to the assessment of systemic risk

§§407 and 408: Adopt rules implementing the exemption from registration for advisers to venture capital firms and to certain advisers to private funds

§409: Adopt rules defining “family office”

§410: Adopt rules and form changes to implement the transition of mid-sized investment advisers (between $25 and $100 million in assets under management) from SEC to State regulation, as provided in the Act

§418: Adopt rules to adjust the threshold for “qualified client”

§417: Report to Congress on the study of the costs and benefits of real time reporting on short sale positions

§413: Adopt rules to revise the “accredited investor” standard

§926: Adopt rules disqualifying the offer or sale of securities in certain exempt offerings by certain felons and others similarly situated

§913: Propose rules as may be appropriate, based on §913 study conducted on the obligations of brokers, dealers and investment advisers

§§915 & 919D: Report to Congress on Office objectives, with attached report by Ombudsman (subject to funding)

August - December, 2011 (planned)

§619: Adopt rules to implement prohibition on proprietary trading and certain relationships with hedge funds and private equity funds

Dates to be determined (the following activities have been deferred due to budget uncertainty)

§911: Creation of new Investor Advisory Committee

§915 and 919D: Creation and Staffing of Office of Investor Advocate (Activities regarding investor perspectives in rulemaking continuing to be performed by staff in existing Office of Investor Education & Advocacy)

§924: Creation and Staffing of Whistleblower Office (Functions temporarily assigned to existing staff within the Division of Enforcement)

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