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Investment Management Threshold Requirements

Foley Hoag LLP

QPAM Amendment – Action Required by Investment Managers

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The U.S. Department of Labor (“DOL”) has amended the qualified professional asset manager (“QPAM”) class prohibited transaction exemption 84-14 (“QPAM Exemption”), effective as of June 17, 2024 (“QPAM Amendment”)....more

Seward & Kissel LLP

SEC Adopts Gross Short Position and Activity Reporting by Institutional Investment Managers

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On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted new Rule 13f-2 (the “New Rule”) under Section 13(f)(2) of the Securities Exchange Act of 1934 (the “Exchange Act”), as well as related Form SHO....more

Stinson LLP

SEC Increases Qualified Client Threshold

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In an order effective August 16, 2021, the Securities and Exchange Commission (SEC) increased the dollar amount tests in the "qualified client" definition under Advisers Act Rule 205-3....more

Mayer Brown Free Writings + Perspectives

The SEC Adjusts the “Qualified Client” Tests for Inflation

Effective August 16, 2021, the Securities and Exchange Commission will apply new threshold amounts with respect to the definition of “qualified clients,” raising the starting dollar amounts of the assets-under-management and...more

K&L Gates LLP

SEC Proposes Amendments to Form 13F, Proposes Increasing 13F Reporting Threshold

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On 10 July 2020, the Securities and Exchange Commission (SEC) proposed amending Form 13F and Rule 13f-1 to raise the reporting threshold at which institutional investment managers are required to complete and file Form 13F...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes To Raise Form 13F Reporting Threshold From $100 Million to $3.5 Billion

On July 10, 2020, the Securities and Exchange Commission (SEC) voted 3-1 to approve proposed rules that, among other things, would raise the Form 13F reporting threshold for institutional investment managers (managers) from...more

Lowenstein Sandler LLP

SEC Proposes To Amend Form 13F Reporting Thresholds For Institutional Investment Managers

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On July 10, 2020, the Securities and Exchange Commission (SEC) proposed to raise the Form 13F reporting threshold for institutional investment managers from $100 million to $3.5 billion (the Proposal). Currently, investment...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Amendments to Update Form 13F

The Securities and Exchange Commission (SEC) has recently proposed to amend the reporting threshold and make certain other changes to Form 13F. It should be noted that this is the first time the reporting threshold would be...more

Latham & Watkins LLP

SEC Proposal: Will You Still Be a 13F Filer?

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The SEC proposes a welcome and significant increase in the 13F reporting threshold from US$100 million to US$3.5 billion. On July 10, 2020, the US Securities and Exchange Commission (SEC) released a proposed rule amendment...more

Winstead PC

SEC Proposes Raising Form 13F Institutional Investment Manager Reporting Threshold to $3.5 Billion

Winstead PC on

On July 10, 2020, the Securities and Exchange Commission (“SEC”) announced that it has proposed to amend Rule 13F-1 and Form 13F to raise the reporting threshold for institutional investment managers from $100 million to $3.5...more

Goodwin

Financial Services Weekly News - June 2016 #4

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Regulatory Developments - SEC Issues Order Approving Inflation Adjustments to “Qualified Client” Dollar Thresholds for Investment Adviser Performance Fee Rule - On June 14, the SEC issued an order approving...more

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