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Fifth Circuit Vacates Private Fund Adviser Rules

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

Managers of Plan Asset Funds: Important December 1, 2023 Deadline for DOL's Proxy Voting Rule

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

SEC Adopts New Private Fund Adviser Rules

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

COVID-19 Update—“Essential” Investment Company/Advisory Functions in the Wake of Shelter in Place Orders

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

COVID-19 Update – Limited Form ADV & Form PF Filing Relief

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

2020 Annual Compliance Obligation Reminders

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

The New Standards for Investor Protection: An Analysis of Regulation Best Interest, Form CRS and Two Interpretations of the US...

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

Deadline Approaching for Form TIC SHL

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

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