Under Regulation D Rule 506(c) of the Securities Act of 1933, private funds may generally solicit and advertise their offerings, but all purchasers must be verified as accredited investors before being allowed to invest. ...more
1/15/2026
/ Accredited Investors ,
Division of Corporate Finance ,
JOBS Act ,
New Guidance ,
No-Action Letters ,
Private Funds ,
Regulation D ,
Regulatory Requirements ,
Rule 506(c) ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC)
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury (the “Treasury”), issued a final rule (the “Final Rule”), adding investment advisers to the definition of “financial...more
1/9/2026
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Time Extensions
As financial markets and investors increasingly rely on instant access to data online, financial professionals are publishing more analyses through websites and social media than ever before. ...more
12/2/2025
/ Anti-Fraud Provisions ,
Content Publishing ,
Exemptions ,
Financial Markets ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Online Platforms ,
Registration Requirement ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Social Networks
Senate Bill No. 17 becomes law on September 1, 2025.
On June 20, 2025, Governor Abbott signed Senate Bill No. 17 to prohibit the purchase or acquisition of interests in real property by individuals domiciled in and...more
As promised, FinCEN has adopted its interim final rule and narrowed the filing requirements for Beneficial Ownership Information (“BOI”) reporting under the Corporate Transparency Act (“CTA”). This rule exempts U.S. entities...more
4/8/2025
/ Beneficial Owner ,
Business Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Disclosure Requirements ,
Domestic Corporations ,
Filing Deadlines ,
FinCEN ,
Foreign Corporations ,
Reporting Requirements ,
U.S. Treasury
FinCEN and the Department of the Treasury both provided updates this week regarding the Corporate Transparency Act....more
Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are now back in effect. As a result, all entities subject to the CTA are once again obligated to file BOI reports with...more
On January 23, 2025, the United States Supreme Court granted the government’s application for stay of a recent district court’s preliminary injunction of the enforcement of the Corporate Transparency Act (CTA)....more
Late on December 26, 2024, a panel of the Fifth Circuit ordered the injunction back into effect. Timing is uncertain for any oral arguments or other court rulings....more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
This is still a developing matter. On December 23, 2024, the Fifth Circuit issued an order that has the effect of reinstating FinCEN’s ability to enforce the CTA and the looming December 31 deadline to file reports for any...more
After our December 23 News Alert, FinCEN announced an extension for all filings due by 12/31/2024 for entities formed prior to January 1, 2024. Such subject entities now must file no later than January 13, 2025....more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Injunctions ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
On December 3, 2024, the U.S. District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementation of regulations nationwide....more
On January 1, 2024, the new reporting requirements under the Corporate Transparency Act (the “CTA”) took effect in the United States. The CTA, aimed at increasing corporate transparency and combating financial crimes,...more
The U.S. Department of Labor’s (the “DOL”) amendment to the qualified professional asset manager (“QPAM”) prohibited transaction class exemption 84-14 (the “Exemption”) went into effect on June 17, 2024. Current QPAMs must...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
Last week, the U.S. Securities and Exchange Commission brought five insider-trading cases against a slew of individuals. The U.S. Attorney’s Office for the Southern District of New York also announced parallel criminal...more
Recent Enforcement Action -
The requirement that financial firms preserve books and records is nothing new. But how do such firms keep track of employees’ communications on applications like Signal or WhatsApp? Those...more
On February 9, 2022, the Securities and Exchange Commission (SEC) proposed new rules and amendments under the Investment Advisers Act of 1940 (Advisers Act) to enhance the regulation of private fund advisers. The proposed new...more
On August 16, 2021, the financial thresholds specified in the definition of “qualified client” under Rule 205‑3 of the Investment Advisers Act of 1940 (“Advisers Act”) will increase (i) from $1 million to $1.1 million (assets...more
On April 1, 2021, the Texas State Securities Board (TSSB) announced the entry of a Consent Order against an SEC registered investment adviser named Independent Financial Group, LLC (“Independent”). The TSSB’s action may...more
As we discussed in our recent post “What to Expect from the SEC Under the Biden Administration,” market participants can expect a more vigorous SEC enforcement program under the new administration. President Biden’s nominee...more
3/11/2021
/ Asset Valuations ,
Biden Administration ,
Conflicts of Interest ,
Disclosure Requirements ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Fees ,
Fund Managers ,
General Solicitation ,
Investment Adviser ,
Personal Information ,
Securities and Exchange Commission (SEC) ,
Transparency
The Securities and Exchange Commission (the “SEC”) recently adopted amendments to the definition of “accredited investor,” which will permit a wider range of investors to participate in certain private offerings. The amended...more
11/12/2020
/ Accredited Investors ,
Family Offices ,
Investment Advisers Act of 1940 ,
Investors ,
Knowledgeable Employee ,
Limited Liability Company (LLC) ,
Private Offerings ,
Qualified Institutional Buyers ,
Regulation D ,
Rule 501(a) ,
Rural Business Investment Companies (RBICs) ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC)