Heather S. Cruz

Form PF: Final Rules Adopted by the SEC and the CFTC
Geoff Bauer,Heather S. Cruz,Lawrence D. Frishman,Eric Requenez,Anastasia T. Rockas, May 1, 2012
On November 16, 2011, the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC”) published in the Federal Register final rules requiring registered advisers to private funds to report certain information on Form PF. Form PF...

Registration of Advisory Entities Affiliated With a Registered Investment Adviser
Heather S. Cruz,Andrew D. Deas,Lawrence D. Frishman,Anastasia T. Rockas, February 14, 2012
On January 18, 2012, the Division of Investment Management of the Securities and Exchange Commission (the “SEC”) issued a no-action letter (the “No-Action Letter”) in response to a request from the American Bar Association’s Subcommittee on Hedge Funds (the “ABA...

European Securities and Markets Authority Publishes New Guidelines to Apply From May 2012 for Regulation of Automated and Algorithmic Trading in the EU
James Anderson,Patrick Brandt,Heather S. Cruz,Philip H. Harris,Stephen G. Sims,Mark D. Young, January 18, 2012
On 22 December 2011, the European Securities and Markets Authority (“ESMA”) published guidelines (the “Guidelines”) on EU electronic trading systems, trading algorithms and the provision by investment firms of direct market or sponsored trading system access. ESMA is the...