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SEC Provides Helpful Marketing Rule FAQ Guidance

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

Third Set of Form PF Amendments Take Effect on June 12, 2025

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

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

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 – 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

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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