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SEC Staff Updates FAQs Regarding Marketing Rule Compliance – Gross and Net Performance

On March 19, 2025, the staff of the Division of Investment Management (the “SEC Staff”) of the Securities and Exchange Commission (the “SEC”) released an update to its Frequently Asked Questions1 (the “FAQs”) relating to...more

SEC Charges Crypto Firm with Custody Rule Violations and Misleading Fund Investors on the Timing of Redemption Notices

On September 3, 2024, the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against Galois Capital Management LLC (“Galois”), a Florida-based former registered investment adviser, for failing to...more

T+1 Settlement Cycle: Implications for Investment Advisers

Starting May 28, 2024, the settlement cycle for most transactions in U.S. securities will shorten from T+2 to T+1 as a result of rule amendments adopted by the Securities and Exchange Commission (SEC).1 The SEC also adopted a...more

SEC Staff Releases FAQ on Marketing Rule Compliance – Calculating Gross and Net Performance

On February 6, 2024, the SEC’s Division of Investment Management (SEC Staff) released an update to frequently asked questions document (FAQ) regarding amendments to rule 206(4)-1. The SEC Staff responses to the FAQ’s...more

Compliance Dates for Final Rules Regarding the Regulation of Private Fund Advisers

On August 23, 2023, the Securities and Exchange Commission (the “SEC”) adopted new final rules and amendments to existing rules under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) with respect to the...more

SEC Charges FinTech Investment Adviser with First Violation of the Marketing Rule and Additional Compliance Violations

Recently, the U.S. Securities and Exchange Commission (the “SEC”) announced charges against an investment adviser (the “Adviser”) for using hypothetical performance metrics in advertisements that were misleading pursuant to...more

The SEC Adopts Final Rules Regarding the Regulation of Private Fund Advisers

On August 23, 2023, by a vote of 3-2, the Securities and Exchange Commission (the “SEC”) adopted new final rules and amendments to existing rules under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) with...more

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