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SEC’s First Liquidity Rule Enforcement Action Signals New Focus

On May 5, 2023, the Securities and Exchange Commission (the “SEC”) announced its first enforcement action against an investment adviser for violations of Rule 22e-4(b) (the “Liquidity Rule”) of the Investment Company Act of...more

SEC Continues Focus on Conflicts Disclosures in Enforcement Actions Totaling $106 Million in Fines and Disgorgement

The U.S. Securities and Exchange Commission (the “Commission”) recently entered into four consent orders (collectively, the “Orders” and each, an “Order”) with registered investment advisers (“RIAs” and each, an “RIA”) that...more

Recent Enforcement Action Provides Helpful Guidance in Several Areas for Advisers to Private Funds

In April and May 2020, the Securities and Exchange Commission (the “Commission”) entered a series of settled Orders assessing fines, instituting a bar, and ordering remedial action against registered investment advisers...more

SEC Releases Cryptocurrency and Digital Asset Guidance

The SEC published guidance with respect to cryptocurrencies, digital tokens, and similar investments (each a “digital asset”) that is designed to help issuers and others determine whether the applicable digital asset is a...more

Investment Management Regulation: Year in Review

As we prepare for a new year of regulatory initiates and actions, we believe it is important to take inventory of the most significant regulatory events from the past year. True to its word, the SEC focused on reducing...more

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