SEC Charges 21 Advisers For Form CRS Failures – Impact On Private Fund Managers

On July 26, 2021, 21 investment advisers entered into settlements with the Securities and Exchange Commission to resolve charges that they failed to timely file and deliver their relationship summaries on Form CRS.1 Penalties ranged from $10,000 to $97,523 per firm.

Form CRS, adopted by the SEC on June 5, 2019, is a “relationship summary” that registered investment advisers were initially required to deliver to retail investor clients (and prominently post on their websites) by June […]

By | July 28th, 2021 ||

Rationalizing Lending Authorities

One of Jason’s favorite restaurants is Queen’s English in the Columbia Heights neighborhood of Washington, DC. He patronizes it often enough that the servers don’t need to give him a menu; he is committed to consume whatever dishes chef Henji Cheung and his wife Sarah Thompson, who commands the front of the house, send his way.

The dining room accommodates fewer than 40 guests at a time, and Henji often orders ingredients with his regulars […]

By | July 20th, 2021 ||

Banking And Cannabis: Bank Lending, The Next Frontier

A fortuitous combination of developments and circumstances present the banking and cannabis industries a large opportunity to enhance each of their respective bottom lines: conventional bank lending, payment processing, treasury management and other services, and bank administered SBA and revenue bond financing to cannabis businesses.

Loan numbers are difficult to come by, but knowledgeable sources estimate that borrowing for “plant touching” cannabis, businesses (e.g., growers, processors, retailers, testing labs and delivery services) was at least […]

By | July 12th, 2021 ||