To View in Browser or from a BlackBerry, click here.


ATTORNEY ADVERTISING
Summer 2010
LOWENSTEIN SANDLER INVESTMENT MANAGEMENT GROUP CLIENT UPDATE

Lowenstein Sandler's Investment Management Group is pleased to provide you with a summary update regarding recent legislative and regulatory developments that may have a significant impact on the investment community, as well as information regarding upcoming events that may be of interest to investment professionals. For more information regarding any of these developments or events, please contact one of the attorneys listed or another member of the Investment Management Group. ______________________________________________________________________________

NOTEWORTHY LEGISLATIVE AND REGULATORY DEVELOPMENTS

SEC Redesigns Form ADV, Part 2: Expanded, Narrative-Style Disclosure Will be Publicly Available on SEC Website

Synopsis: On July 28, 2010, the SEC released final amendments to Form ADV, Part 2, the principal disclosure document that federally registered investment advisers must provide to their clients and prospective clients. Among other changes, the amendments mandate (i) expanded disclosures presented in a plain English narrative, (ii) electronic filing to permit public review and comparison on the SEC website and (iii) delivery of "Brochure supplements" containing resume-like information regarding advisory personnel providing services to clients. According to SEC Chairman Mary Schapiro, the new rules are designed to "transform the brochure into a plain English narrative that is well-suited to serve investors' needs—a narrative that will describe the adviser's conflicts, compensation, business activities, and disciplinary history."1 Chairman Schapiro also expressed her hope that the enhanced disclosure requirements "may result in advisers modifying business practices and compensation policies which might pose conflicts, in ways that better serve the interests of clients."2

Status: The new Form ADV, Part 2 requirements become effective 60 days after publication in the Federal Register and must be implemented as follows:

  • Advisers applying for registration with the SEC after January 1, 2011 must file a Form ADV, Part 2 that complies with the new rules and form, and deliver to clients and prospective clients a brochure and supplements meeting the requirements after that date.

  • Registered advisers with a fiscal year end of December 31, 2010 must file a new Form ADV, Part 2 in compliance with the new rules no later than March 31, 2011 and deliver to new clients and prospective clients an updated brochure and supplements within 60 days of the filing.

SEC "Pay to Play" Rules Restrict Political Contributions by Investment Advisers

Synopsis: On June 30, 2010, the SEC adopted new Rule 206(4)-5 and amendments to related rules, which prohibit investment advisers, their key personnel and placement agents acting on their behalf, from making political contributions. Prohibited contributions are defined as "any gift, subscription, loan, advance, or deposit of money or anything of value," and the ban extends to the solicitation of such contributions (such as hosting fundraising events). The investment adviser and their "covered associates" are prohibited from making contributions in any amount; provided however, that, pursuant to a "de minimis" exception, covered associates may annually contribute up to $350 per candidate in elections in which the covered associate is entitled to vote, and up to $150 per candidate in elections in which the covered associate is not so entitled. Contributions are disqualifying if made to a candidate for, or holder of, a government office that has the power to "directly or indirectly" hire an investment adviser, influence the hiring decision, or appoint other officials who can hire the adviser or influence such decision. Under the new rule, even a single prohibited contribution in any amount may result in an effective two-year disqualification of the investment adviser from providing services to or accepting investments from a government client or plan.

Status: The new rules become effective on September 13, 2010.3 The Lowenstein Sandler Investment Management Group Client Alert issued August 6, 2010 discussing the new prohibition in greater detail can be found here.

Dodd-Frank and "Volcker Rule" Become Law

Synopsis: On July 21, 2010, President Obama signed into law a comprehensive financial reform package known as the Dodd-Frank Wall Street Reform and Consumer Protection Act. Passage of the Dodd-Frank bill reflected approval of a reform package that emerged from a joint congressional conference committee that had been reconciling separate financial industry regulatory reform proposals passed by the House in December 2009 and the Senate in May of this year. Significant areas of regulatory reform include:

  • financial stability and regulation of "too big to fail" institutions;
  • orderly liquidation procedures for troubled financial institutions;
  • regulation of advisers to hedge funds and other private investment vehicles (including private equity funds);
  • regulation of over-the-counter derivatives;
  • regulations concerning executive compensation and corporate governance;
  • creation of a Consumer Financial Protection Bureau; and
  • creation of a Financial Stability Oversight Council.

Of particular importance to investment advisers, Title IV of the Dodd-Frank bill contains a comprehensive overhaul of the registration regime. The bill eliminates the so-called "private adviser exemption" contained in Section 203(b)(3) of the Investment Advisers Act of 1940 that currently exempts from registration investment advisers with fewer than fifteen clients that do not hold themselves out to the public as investment advisers. Additionally, the new legislation generally provides that any investment adviser that acts solely as an adviser to private funds and has assets under management in the United States of less than $150 million, shall be exempt from the registration requirements under the Advisers Act. However, the Dodd-Frank bill directs the SEC to require such advisers to maintain records and provide to the SEC any reports that the SEC determines are "necessary or appropriate in the public interest or for the protection of investors." The Dodd-Frank bill directs the SEC to adjust the individual net worth standard for accredited investors so that such individual’s net worth (or joint net worth with such person's spouse) excludes the value of a primary residence.

The Volcker Rule

As originally proposed, the Volcker Rule would have strictly prohibited banks from trading their own proprietary accounts and engaging in private fund sponsorship and investment activities. While the Volcker Rule remains a fundamental part of the new legislation and contains extensive restrictions on proprietary trading and private fund sponsorship and investment, the final form of the bill includes significant exceptions to the original prohibitions as well as extended transition periods for compliance. The Volcker Rule’s statutory ban on proprietary trading by banking entities covers any security, any derivative, any future, any option on any of the foregoing, or any other security or financial instrument designated by rule by the federal regulators. As is the case with other elements of the legislation, the prohibition on proprietary trading is subject to a list of exceptions, referred to in this section of the statute as "permitted activities." Permitted activities include, but are not limited to (i) transactions in many U.S. government securities; (ii) transactions "in connection with underwriting or market making-related activities, to the extent that any such activities ... are designed not to exceed the reasonably expected near term demands of clients, customers or counterparties"; (iii) transactions "on behalf of customers"; and (iv) "risk mitigating hedging activities." The Volcker Rule's prohibition on sponsorship of or investment in hedge funds and private equity funds has similarly been scaled back. Among other permitted activities, banking entities may still make "de minimis" investments in private funds that they organize or sponsor to the extent such investments constitute (i) not more than 3% of the total ownership of such fund within one year of the fund's establishment and (ii) not more than 3% of such banking entity’s Tier 1 capital.

The Lowenstein Sandler Investment Management Group Client Alerts analyzing the House bill, the Senate bill and the Dodd Frank Act as ultimately adopted are available here, here and here, respectively.

Status: This comprehensive landmark legislation contemplates an extraordinary amount of rule-making by various Federal agencies in the months and years following the July enactment. While certain of the elements of the new law become effective immediately upon passage (e.g., the accredited investor standard), there are substantial transition periods associated with many of the most important parts of the law. For instance, the elimination of the “private adviser exemption” becomes effective in July 2011 (one year after enactment) and the Volcker Rule will not become effective until approximately two years after enactment.

The Wall Street Transparency and Accountability Act of 2010

Synopsis: The Wall Street Transparency and Accountability Act of 2010 is Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Subtitles A and B of the Act deal with the regulation of over-the-counter derivatives. Under the derivatives provisions, both bank and non-bank major participants in the derivatives markets will be designated as either swap dealers or major swap participants and will be subject to:

  • registration requirements;
  • capital and margin requirements;
  • mandatory clearing and execution requirements; and
  • reporting and recordkeeping requirements.

Swap dealers and major swap participants must register with the Securities and Exchange Commission (SEC) and/or the Commodity Futures Trading Commission (CFTC) or both. The registration requirements will take effect within 360 days after the Act's enactment.

The SEC and the CFTC are directed to adopt comparable rules and regulations setting forth the capital and margin requirements for uncleared swaps, in both cases taking into account that uncleared swaps pose a greater threat to the financial system than do cleared swaps. For cleared swaps, Derivatives Clearing Organizations (DCO) will determine the minimum levels of initial and variation margin. DCOs must be registered with the SEC and/or the CFTC, and must comply with the Act and any rules and regulations promulgated by the SEC and/or CFTC.

Status: The registration requirements take effect in July 2011. The capital and margin, clearing and execution, and reporting and recordkeeping requirements will not become effective until the required implementing rules and regulations are published by the SEC and CFTC. The Lowenstein Sandler Investment Management Group Client Alert describing the major provisions of The Wall Street Transparency and Accountability Act of 2010 can be found here.

Tax Extenders Bill Would Raise Taxes on "Carried Interest"

Synopsis: On May 28, 2010, the House of Representatives passed the "American Jobs and Closing Tax Loopholes Act," a multi-billion dollar "mini-stimulus" bill that would be funded in part through an increase of the tax rate applicable to carried interest. While carried interest has historically been taxed at the capital gains rate of 15%, the House bill would treat 75% of carried interest as ordinary income subject to tax rates as high as 35% (which may increase further to 39.6% if the Bush-era tax cuts are allowed to expire at 2010 year end). The remaining 25% of carried interest would continue to be taxed at the capital gains rate (which may increase from 15% to 20% if the Bush-era tax cuts are allowed to expire at 2010 year end).

Status: Under the House bill, the carried interest tax provisions would take effect on January 1, 2011. The Senate has considered three modified versions of the carried interest legislation. The last version failed on a procedural vote on June 23, 2010. However, enactment of carried interest legislation this year, either as part of the "tax extenders" bill that is expected to be taken back up later this year or as a revenue offset to other legislation, remains a distinct possibility. The full text of the bill as passed by the House can be found here.

SEC Announces Examination Initiative for Unexamined Investment Advisers

Synopsis: During a June 7, 2010 meeting of the National Society of Compliance Professionals, Norm Champ, the Associate Regional Director for Examinations at the SEC’s New York office, announced that the SEC anticipated sending document requests to approximately 48 registered investment advisers in New York and New Jersey that had not been previously examined by the SEC. The document requests, while shorter than lists normally used for routine investment adviser examinations, reflect a more active regulatory stance by the SEC in the wake of the financial meltdown. These efforts by the SEC's New York office appear to be part of a regulatory initiative being pursued in other regional offices such as Chicago.

Status: The SEC's New York Office began sending its document requests in mid-June. It is expected that the SEC will use investment adviser responses to the document requests as a guide for more targeted examinations.

Recent SEC Examinations Are Covering Reduced Review Periods

Synopsis: We note anecdotally that, in certain recent routine SEC examinations, investment advisers have received request lists for audit/review periods significantly shorter than the traditional one- or two-year periods. Recent initial SEC examination request lists have shortened the review period to as short as three months.

Status: As there has been no formal pronouncement from the SEC, investment advisers would be well-advised to continue to position themselves for a more extensive and traditional review period, and should conduct their compliance program and recordkeeping and production capability accordingly.

SEC Approves Stock-By-Stock Circuit Breaker Rules in Wake of May 6, 2010 "Flash Crash"

Synopsis: On June 10, 2010, the SEC approved new stock-by-stock circuit breaker rules that were recommended as a preventative measure for events such as the "flash crash" of May 6, 2010. The rules require securities exchanges and FINRA to pause trading for five minutes in certain individual securities if the price of such securities moves 10% or more in any direction within any five-minute period. The rules will only apply during the period from 9:45 a.m. until 3:35 p.m. for each trading day. The rules are structured as a temporary pilot program that is slated to end on December 10, 2010, after which the SEC, FINRA and the exchanges will assess the effectiveness of the program.

Status: The securities exchanges and FINRA began implementing the circuit breaker rules in June. The SEC's press release announcing the adoption of the rules, as well as links to the SEC's orders relating to the circuit breaker rules, can be found here.

Enforcement of Red Flags Rule Postponed Until December 31, 2010

Synopsis: On May 28, 2010, the Federal Trade Commission announced that it would postpone enforcement of its "Red Flags Rule" until December 31, 2010. The Red Flags Rule, which had previously been slated to take effect on June 1, 2010, would require the development and implementation of written identity theft prevention programs by creditors and financial institutions. The Red Flags Rule was promulgated pursuant to the Fair and Accurate Credit Transactions Act of 2003 and may require advisory firms and broker-dealers to strengthen their current privacy policies and implement effective identity theft programs. The Lowenstein Sandler Investment Management Group Client Alert issued January 6, 2009 analyzes the Red Flags Rule and its potential applicability to broker-dealers. The Federal Trade Commission has provided a website containing helpful resources relating to the Red Flags Rule. The website is available here.

SEC and CFTC Form Joint Committee to Address Emerging Regulatory Issues

Synopsis: On May 11, 2010, the SEC and the CFTC announced the creation of the Joint SEC-CFTC Committee on Emerging Regulatory Issues. In statements, the respective Chairs of each agency discussed the manner in which their respective regulatory responsibilities have become intertwined as the driving force behind the creation of the joint committee. The joint committee will be charged with identifying emerging regulatory risks, assessing the possible implications of such risks for investors and market participants, and making recommendations for a coordinated regulatory strategy. The creation of the joint committee was one of 20 recommendations made in a 2009 joint harmonization report issued by the agencies. The SEC release announcing the establishment of the joint committee can be found here. The Lowenstein Sandler Investment Management Group Client Alert discussing the 2009 joint harmonization report can be found here.

Status: On May 18, 2010, the joint committee announced that it would issue a detailed analysis of the events of May 6, 2010 that caused the "flash crash" (resulting SEC rules from such analysis are discussed in more detail above). The joint committee’s report on the "flash crash" can be found here.

Connecticut Senate Rejects Proposal to Regulate Investment Funds

Synopsis: On May 9, 2010, the Connecticut State Senate rejected a proposal that would have required investment advisers that are either located in Connecticut or that offer or sell securities in Connecticut to disclose material conflicts of interest to their investors or potential investors. The measure failed despite having previously been approved by the Connecticut House of Representatives in 2009.

Status: The bill failed approximately one year after a similar proposal stalled in the Connecticut House of Representatives in 2009 after winning approval in the Connecticut Senate.

SEC Emphasizes Aggressive Enforcement Stance in Testimony Before Subcommittee on Financial Services and General Government

Synopsis: On April 28, 2010, SEC Chair Mary Schapiro testified before the Senate Subcommittee on Financial Services and General Government, a division of the Senate Committee on Appropriations. Her remarks emphasized the renewed focus on enforcement that has defined the SEC in the wake of the financial crisis, both by highlighting the recent reorganization of the agency into enforcement units and by statistics showing increased actions and settlements. Reportedly, the Asset Management unit, one of the new enforcement units created by the SEC earlier this year (which includes the Market Abuse unit, the Structured and New Products unit, the Foreign Corrupt Practices unit and the Municipal Securities and Public Pensions unit), has begun an investigation into the use of “side pockets” by investment fund managers.

Status: The opening remarks of the testimony are available in full here.

Proposed Canadian Securities Act Would Federalize Capital Markets Regulation

Synopsis: On May 26, 2010, the Canadian Department of Finance released a proposal that would create a harmonized national regulatory regime for capital markets in Canada. In its current form, if enacted, provincial participation in the federal regulatory regime would be voluntary. Among other items, the proposal would establish a federal regulatory authority and allow for the federal designation and recognition of self-regulatory organizations, exchanges, clearing agencies and auditor oversight organizations. The proposal would also establish a federal framework for the regulation of derivatives, with more detailed rules relating to derivatives to be adopted at a later time.

Status: The Canadian Securities Act proposal has been referred to the Supreme Court of Canada for consideration regarding its constitutionality.

European Union Moves Forward in Its Effort to Increase Regulation of Investment Funds

Synopsis: On May 17, 2010, a European Parliament committee approved new regulations applicable to non-European Union investment funds seeking to raise money from EU investors. The following day, EU finance ministers approved a similar proposal. If enacted, the EU proposals would require investment managers of non-EU investment funds to comply with disclosure obligations comparable to those contained in the U.S. financial reform proposals. In addition, the regulations would impose leverage limits, ban naked short sales of certain debt and financial stocks, and impose limits on compensation for fund executives. Most controversially, the proposal could significantly impair the ability of non-EU funds to operate within the EU, either by requiring each fund to file individual applications to operate in particular EU countries, or by requiring funds to obtain a "passport" to operate within the EU generally. To be eligible for a passport, a fund would be required to demonstrate that it is in compliance with EU risk, leverage, compensation and other requirements.

Status: The EU Parliament committee and finance ministers approved the above proposals despite fierce opposition from industry lobbyists in the U.S. and London, which is the seat of over 70% of non-EU hedge funds. However, the EU measures will need to be reconciled and approved in a final version before they are eligible to become law, a process that has led to weekly talks among representatives of the EU Parliament, European Commission, and EU member states throughout the summer. Reportedly, the sides are considering a compromise proposal that would allow funds to elect either to apply for an EU-wide "passport" or to continue to operate under country-specific rules for fund operations. Under the compromise, funds would have to comply with the disclosure and transparency requirements described above to be eligible for the passport, but non-EU funds would not be required to obtain a passport to market to investors within the EU. If this compromise is adopted, a final vote on the measure could come as early as September, with the new system slated to begin in January 2011.  

____________________________________________________________________________________
1Mary L. Schapiro, Speech by SEC Chairman: Opening Statement at the SEC Open Meeting—Form ADV Amendments (July 21, 2010), available at http://www.sec.gov./news/speech/2010/spch072110mls-adv.htm.
2Id.
3The complete text of new Rule 206(4)-5 and amendments to Rules 204-2 and 206(4)-3 can be found at Political Contributions by Certain Investment Advisers, 75 Fed. Reg. 41,018 (July 14, 2010) (to be codified at 17 C.F.R. pt. 275), available at http://edocket.access.gpo.gov/2010/pdf/2010-16559.pdf.

RECENT PUBLICATIONS AND COMMENTARY

Below are titles and links to certain recent articles and Investment Management Group publications that may be of interest to members of the investment community. For additional information, please contact a member of the Investment Management Group.

UPCOMING EVENTS

Below is information regarding upcoming events that may be of interest to investment professionals. For more information regarding any of these events, please contact events@lowenstein.com or a member of the Investment Management Group.

  • IVY Plus Private Equity and Hedge Fund Networking Group
    Date/Time:
    August 31, 2010
    Location: Lowenstein Sandler, Board Room, 19th Floor, New York City
    Lowenstein Sandler's Investment Management Group will host the IVY Plus private equity and hedge fund networking group. Attendees will include representatives from private equity firms, hedge funds, family offices and other financial institutions.

  • The Regulatory, Compliance and Tax Environment for Fund Managers
    Date/Time: September 28, 2010 12:30 - 1:30 PM EST
    Location: Webcast
    Lowenstein Sandler's Investment Management Group is proud to present a webcast on "The Regulatory, Compliance and Tax Environment for Fund Managers." The Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law by President Obama on July 21, 2010. The Act and other recent legislative reform efforts seek to tackle the global financial crisis by reforming key areas of the financial services industry. Among such reforms are amendments to the laws governing investment funds. This live webcast will include updates and recent developments on the following topics: Financial Reform, Volcker Rule and Fiduciary/Bank Standards, Pay to Play Practices and Amendments to Form ADV Part 2, Examination and Enforcement Priorities, Carried Interest Legislation, and Implications for Fund Structuring and Management. Attorneys Marie T. DeFalco, Elaine M. Hughes, David L. Goret and Scott H. Moss will be presenting.

  • Dow Jones Private Equity Analyst Conference 2010
    Date/Time: September 28-29, 2010
    Location: The Waldorf-Astoria, New York City
    Lowenstein Sandler's Investment Management Group will attend the Dow Jones Private Equity Analyst Conference in New York. Recognized as the industry’s premier networking event, the Dow Jones Private Equity Analyst Conference brings together over 800 influential players in private equity, including leading experts and more than 150 LPs, through focused breakouts, receptions and in specially-designed interactive sessions.

  • IVY Plus Private Equity and Hedge Fund Networking Group
    Date/Time: September 28, 2010
    Location: Lowenstein Sandler, Board Room, 19th Floor, New York City
    Lowenstein Sandler's Investment Management Group hosts the IVY Plus private equity and hedge fund networking group. Attendees include representatives from private equity firms, hedge funds, family offices and other financial institutions.

  • 4th Annual Hedge Fund General Counsel Summit - Corporate Counsel
    Date/Time: October 4, 2010
    Location: The Harvard Club of New York, New York City
    Lowenstein Sandler's Investment Management Group is a proud sponsor of the 4th Annual Hedge Fund General Counsel Summit. This event will address the impending changes and offer concrete guidance on how funds need to be run to ensure compliance and to attract investor capital. Peter D. Greene, Vice Chair of Lowenstein Sandler's Investment Management Group, will be moderating a panel discussion titled "Investor Needs, Fears, and Protection." This discussion will cover topics including: understanding your investors' concerns in today's economy and with today's guarded view of the financial markets; ensuring investor protection; due diligence: what do they need from you and what do you have to provide?; and investors and legal risks. Marie T. DeFalco, Vice Chair of Lowenstein Sandler's Investment Management Group, David L. Goret and Matthew A. Magidson, Members of Lowenstein Sandler's Investment Management Group, will be attending.

  • Managed Funds Association - Outlook 2010
    Date/Time: October 7-8, 2010
    Location: The Pierre Hotel, New York City
    Lowenstein Sandler's Investment Management Group is proud to sponsor MFA's hedge fund leadership conference, Outlook 2010. Outlook's program agenda is designed for MFA's hedge fund members and a faculty of policy makers and prominent speakers to engage in meaningful dialogue about the state of the hedge fund industry and the critical issues that may transform the industry in the future. Marie T. DeFalco, Vice Chair of Lowenstein Sandler's Investment Management Group, and Scott H. Moss, Member of Lowenstein Sandler's Investment Management Group will be attending.

  • The Wall Street Transparency and Accountability Act of 2010: What This Law Will Mean To Hedge Funds That Trade OTC Derivatives - Webcast
    Date/Time: October 12, 2010 12:30 - 1:30 PM EST
    Location: Webcast
    The Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law by President Obama on July 21, 2010. The Act seeks to deal with the global financial crisis by reforming key areas of the financial services industry. Among such reforms are major amendments to the laws governing derivatives. Lowenstein Sandler will be presenting a live webcast that will explain some of the major provisions of the Wall Street Transparency and Accountability Act of 2010, and what this law will mean to hedge funds that trade OTC derivatives. Topics currently on the agenda for discussion include: Swap Dealer/Major Swap Participant Classification, Margin and Capital Requirements, Clearing Requirements, Reporting and Recordkeeping Requirements, Unintended Consequences, Other Provisions with Significance to Hedge Funds. Topics are subject to change based on market, legal and regulatory developments. Attorneys Mathew A. Magidson and Karen Abraham will be presenting.

  • Loan Syndications and Trading Association’s (LSTA) Annual Conference
    Date/Time: October 13, 2010
    Location: Hilton Hotel, New York City
    Lowenstein Sandler's Investment Management Group is proud to sponsor the LSTA's Annual Conference. The LSTA is a not-for-profit organization whose mission is to promote a fair, orderly and efficient corporate loan market and provide leadership in advancing the interests of all market participants. Member firms include commercial banks, investment banks, mutual funds, CLO fund managers, hedge funds, buy-side institutions, sell-side institutions, law firms, accounting firms, brokers, loan traders and work-out officers.

  • IVY Plus Private Equity and Hedge Fund Networking Group
    Date/Time: October 26, 2010
    Location: Lowenstein Sandler, Board Room, 19th Floor, New York City
    Lowenstein Sandler's Investment Management Group hosts the IVY Plus private equity and hedge fund networking group. Attendees include representatives from private equity firms, hedge funds, family offices and other financial institutions.

  • Women's Alternative Investment Summit 2010
    Date/Time: November 5-6, 2010
    Location: The Pierre Hotel, New York City
    Lowenstein Sandler's Investment Management Group will attend the 2nd Annual Women's Alternative Investment Summit in New York. The Women's Alternative Investment Summit brings together leading institutional investors and veterans in alternative investments to share their unique perspectives on fundraising, deal flow, portfolio management, liquidity and the challenging road ahead. Marie T. DeFalco, Vice Chair of Lowenstein Sandler's Investment Management Group and Elaine M. Hughes, Member of Lowenstein Sandler's Investment Management Group, will be attending.

Lowenstein Sandler's Investment Management Group proudly supports:

Hedge Funds Care, a national charity founded to prevent and treat child abuse. To support this worthy organization, click here: Hedge Funds Care - Preventing and Treating Child Abuse.
Contact Us
 
www.lowenstein.com
 
New York
1251 Avenue of the Americas
New York, NY 10020
212.262.6700
Palo Alto
590 Forest Avenue
Palo Alto, CA 94301
650.433.5800
Roseland
65 Livingston Avenue
Roseland, NJ 07068
973.597.2500
 
© 2010 Lowenstein Sandler PC. In California, Lowenstein Sandler LLP