On March 12, 2025, the staff of the Securities and Exchange Commission (“SEC”) issued no-action guidance providing that certain minimum investment amounts, along with certain written representations from the purchaser, could...more
On March 19, 2025, the Securities and Exchange Commission (“SEC”) updated its frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). The new FAQs permit...more
On February 8, 2024, the SEC adopted its third set of amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. The amendments specifically affect Sections 1 and 2...more
In a 3-0 decision, the Fifth Circuit Court of Appeals vacated the SEC’s private fund adviser rules (“Final Rule”). Each component of the Final Rule was vacated, including the Private Fund Audit Rule, Private Fund Quarterly...more
Background of Proxy Voting Requirements -
On December 1, 2022, the U.S. Department of Labor (“DOL”) released its final rule regarding investment duties of fiduciaries under ERISA (referred to as the “ESG Rule”). The ESG...more
A divided SEC adopted numerous reforms for private fund managers on August 23, 2023. These reforms represent the largest regulatory change for private fund managers since Dodd-Frank. The SEC’s stated purpose is to bring...more
In an effort to contain the spread of COVID-19, several state and local governments (and more are soon to follow) have taken the unprecedented action of issuing “stay at home” or “shelter in place” orders that mandate the...more
On March 13, 2020, the Securities and Exchange Commission (“SEC”) issued an exemptive order providing temporary relief from Form ADV and Form PF filing obligations applicable to registered investment advisers and...more
Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) or with a state, as well as commodity pool operators and commodity trading advisors registered with the U.S. Commodity Futures Trading...more
2/11/2020
/ CFTC ,
Chief Compliance Officers ,
Commodity Trading Advisors (CTAs) ,
Compliance ,
CPO ,
Filing Deadlines ,
Filing Requirements ,
Investment Adviser ,
Private Investment Funds ,
Required Forms ,
Securities and Exchange Commission (SEC)
On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted three to one to approve a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with...more
9/13/2019
/ Best Interest Standard ,
Books & Records ,
Broker-Dealer ,
Conflicts of Interest ,
Disclosure Requirements ,
Duty of Care ,
Duty of Loyalty ,
Fiduciary Duty ,
Filing Requirements ,
Form CRS ,
Investment Advisers Act of 1940 ,
Investment Management ,
Investors ,
Recordkeeping Requirements ,
Regulation BI ,
Securities Transactions
U.S. issuers (including private investment funds such as hedge, private equity and venture capital funds) must report certain data regarding holdings of their securities by non-U.S. residents to the U.S. Treasury via Form TIC...more