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CalPERS Proposes Conflict Of Interest Disclosure Regulation

CalPERS recently gave notice that it is proposing to adopt a new rule requiring disclosure of conflicts of interests by consultants and external managers.  Under the California Administrative Procedure Act, Cal. Gov’t Code § 11340 et seq., an agency must include in its initial statement of reasons “the problem the agency intends to address”.  Cal.…

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Supreme Court Decision Underscores The Importance Of Administrative Law

Administrative law is one of the most useful subjects that someone can take in law school.  I say that as someone who has taught the subject.  Earlier this week, the California Supreme Court issued an opinion that illustrates exactly why it can be very helpful to know about Administrative Law. Western States Petroleum Ass’n v. State Bd. of…

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APA Amendments Cause Extension Of Rule 260.204.9 Comment Period

Last December, I wrote this post concerning the Commissioner’s proposed amendments to Rule 260.204.9.   This rule provides an exemption from registration for investment advisers to certain private funds.  The rule as currently in effect was adopted as an emergency regulation. As required by the California Administrative Procedure Act, the Commissioner mailed notice of the proposed rule amendments in…

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