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SEC Adopts New Short Sale Disclosure Rule

On October 13, 2023, the Securities and Exchange Commission adopted new Rule 13f-2 to require monthly reporting of short sale positions and activity data on new Form SHO by institutional investment managers. The new rules...more

CFTC Proposes Changes to Rule 4.7

On September 29, 2023, the CFTC approved a proposal to amend certain provisions of its regulations relating to commodity pools, specifically Rule 4.7. The proposal would be the first major change to Rule 4.7 in over 30...more

SEC Revises Marketing Rule for Registered Investment Advisers

On December 22, 2020, the Securities and Exchange Commission (“SEC”) adopted amendments to existing Rule 206(4)-1 (the “Advertising Rule”) and rescinded Rule 206(4)-3 (the “Cash Solicitation Rule”) under the Investment...more

OCIE's 2020 Exam Priorities — Key Takeaways for Private Fund Managers

Last week, the SEC's Office of Compliance Inspections and Examinations released its 2020 Exam Priorities with a number of areas of interest to private fund managers. OCIE reported that it examined 15% of registered investment...more

SEC Releases Proposal to Revise the Advertising and Cash Solicitation Rules for Investment Advisers

On November 4, 2019, the U.S. Securities and Exchange Commission (the "SEC") issued a release proposing to revise the rules pertaining to investment adviser advertisements and payments to solicitors under the Investment...more

OCIE Issues Risk Alert on Principal and Agency Cross Transactions

On September 4, 2019, the SEC's Office of Compliance Inspections and Examinations (OCIE) released a new risk alert on certain principal and agency cross trading compliance issues identified in deficiency letters in connection...more

A Practical Guide to the Regulation of Hedge Fund Trading Activities

The trading activities of hedge funds raise a number of complex issues under the federal securities laws. Proskauer’s Practical Guide to the Regulation of Hedge Fund Trading Activities offers a concise, easy-to-read overview...more

New California Law Requires Increased Private Fund Fee and Expense Disclosure

Recent state legislative developments in California will require disclosure of certain information by private investment fund managers, primarily in the area of fees and expenses incurred by state and local pension and...more

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