The Private Fund Reform Rule (IA-5955) is arguably the biggest regulatory development for the industry since the Dodd-Frank Act, and will impact both SEC-registered and unregistered private fund managers. With a nearly 660 page Adopting Release, the Final Rules place a weighty burden on compliance professionals to decipher the language and determine next steps for compliance.
Sidley's Chuck Daly and ACA Group's Joshua Broaded will discuss the scope, specific requirements, and practical implications of the Restricted Activities and Preferential Treatment rules. They will explore ways that advisers can comply with the new rules, as well as likely implications for relationships between managers and limited partners.
Counsel, Investment Funds
Chuck Daly is based in Sidley's New York office. He has extensive experience working with traditional and alternative investment advisers on regulatory compliance requirements, structures and programs, ongoing compliance monitoring, testing protocols and the management and coordinating of regulatory exams and reviews. His work with investment advisers focuses on the practical design, implementation and on-going administration of compliance programs for registered and unregistered advisory firms. In providing those services to investment advisers, he has gained experience drafting and editing policies and procedures and disclosure documents for managers offering a multitude of products and investment strategies across a variety of asset classes. Chuck’s regulatory support covers SEC, NFA, CFTC, CME, FINRA, FCA (UK) and CIMA (Cayman) regulations and reporting.
Head of Global Regulatory Compliance
Joshua Broaded, CFA, is the head of ACA’s Global Regulatory Compliance practice. In this role, he is responsible for development and oversight of ACA’s regulatory compliance solutions, which leverage consulting, managed services, and technology. Prior to assuming his current role, Josh launched ACA’s Analysis and Review Center, which provides managed services including electronic communication surveillance, outsourced marketing reviews, and code of ethics administrative support. Josh served as an examiner for the SEC from 2004 to 2007 and became a CFA Charterholder during that period. He earned his Bachelor of Science in Business Administration from the University of Pittsburgh.