In the financial services industry, registered firms are subject to recordkeeping rules that require business-related communications to be captured, retained and monitored by the firm for a specified period. For example, Rule...more
The Corporate Transparency Act, as we have previously reported1, is a new federal law designed to combat money laundering, tax evasion, and other illicit financial activities by requiring “reporting companies” to disclose...more
The U.S. Securities and Exchange Commission (the SEC) adopted Amendments to Form PF (the Amendments) in a three-to-two vote on May 3, 2023, over a decade after Form PF’s initial adoption. SEC Chair Gary Gensler predicted that...more
Cryptocurrencies are one of the fastest growing asset types worldwide. Cryptocurrencies, as an asset class, total over $1.5 trillion in market capitalization. With the rapid growth of this asset type, SEC Chair Gary Gensler...more
On July 10, 2020, the Securities and Exchange Commission (SEC) announced that it has proposed to amend Form 13F and Rule 13f-1 to increase the reporting threshold for institutional investment managers (managers) and to...more
On March 13, 2020, the Securities and Exchange Commission (SEC) issued an order (Original Order) providing relief for certain regulatory filings (specifically, annual updates to Form ADV and periodic filings of Form PF)....more
The National Futures Association (NFA) issued a notice on August 9, 2018, to its members announcing that new disclosures relating to virtual currencies and virtual currency derivatives will be required of NFA members that...more
On July 22, 2015, the U.S. Department of the Treasury issued proposed regulations addressing the tax treatment of certain private equity management fee waivers. These new rules could result in many common management fee...more