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ETFs for ERISA Plans: Operational Barriers and Potential Benefits

Exchange-traded funds (ETFs) have gained an increasing foothold in the wealth-management investment universe, with ETF assets under management currently about half the assets under management of mutual funds. As the ETF...more

SEC Staff Issues Updated Marketing Rule FAQs

SEC Staff published new guidance providing private fund managers and other investment advisers with flexibility to use extracted performance and portfolio/investment characteristics in marketing materials, without cumbersome...more

New SEC Guidance Eases Burden in Rule 506(c) Accredited Investor Verification Requirements

SEC staff issued no-action guidance on Rule 506(c) of Regulation D private securities offerings on March 12, 2025, which should provide issuers with an easier path to rely on Rule 506(c) and solicit and advertise their...more

Five Developments Family Offices Are Watching in 2025

As family offices continue to adapt to economic, financial, and technological changes, several ongoing developments are giving family offices plenty consider heading into 2025, including gift and estate tax exemptions, which...more

SEC Division of Examinations Issues Registered Funds Risk Alert

The US Securities and Exchange Commission’s (SEC’s) Division of Examinations recently issued a Risk Alert citing recent deficiencies observed during examinations of registered funds, including the mischaracterization of...more

ADA Compliant Websites: Uptick in Litigation Against Financial Services Firms, Increased Regulatory Attention

Amid a notable recent uptick in website accessibility cases, both threatened and filed, against financial services companies alleging violations under the Americans with Disabilities Act (ADA) and/or similar state and local...more

Compliance Alert: SEC’s 2025 Examination Priorities

The US Securities and Exchange Commission’s (SEC’s) Division of Examinations released its annual report of examination priorities on October 21, 2024 (the Exam Priorities). The annual Exam Priorities report, which is designed...more

SEC Enforces Beneficial Ownership, Insider Transaction Reporting Requirements; Reminder New 13G Deadlines Now in Effect

Recent actions by the US Securities and Exchange Commission’s (SEC’s) Division of Enforcement highlight the importance of making timely filings pursuant to Sections 13(d), 16, and 13(f) of the Securities Exchange Act of 1934....more

Deciphering FinCEN’s New Anti-Money Laundering Rules for Advisers

On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to anti-money laundering/countering the financing of terrorism...more

SEC Amends Registered Fund Reporting Requirements, Issues Guidance on Liquidity Risk Management Programs

The US Securities and Exchange Commission (SEC), by a 3-2 vote, recently adopted amendments to registered fund reporting requirements on Form N-PORT and Form N-CEN and provided guidance on open-end funds’ liquidity risk...more

SEC Stays Approval of Amendment to FINRA Rule 2210 That Would Allow Projections of Performance

In an unusual move, on July 26, 2024, the Securities and Exchange Commission (SEC) stayed an order that was previously issued by its own Division of Trading and Markets just one week earlier on July 19, 2024. That order...more

Fifth Circuit Vacates SEC Private Fund Adviser Rules in Full

In a unanimous decision published on June 5, 2024, the US Court of Appeals for the Fifth Circuit vacated the entire set of regulations, including amendments to existing rules (collectively, the Rules), adopted by the US...more

FINCEN’s AML Proposal: An Overview for Investment Advisers

Earlier this year, the US Department of the Treasury’s (Treasury’s) Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposal) that would subject investment advisers to anti-money...more

SEC and CFTC Adopt Amendments to Form PF

On February 8, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC and, together with the SEC, the Commissions) voted to adopt amendments to Form PF1 that will impact the...more

Private Funds 2023: The Year in Brief

2023 was a watershed year for the private fund industry, not only because the US Securities and Exchange Commission (SEC) adopted a package of new regulations that will substantially alter the private fund landscape (subject...more

The Trends—and Traps—that Will Shape 2024

At a time marked by themes of “push” and “pull,” organizations across all sectors and jurisdictions are grappling with the pursuit of innovation within an increasingly complex regulatory framework. Over the next 12 months,...more

Five Recent Developments Family Offices Are Watching in 2024

Although family offices have long been exempt from many of the more onerous regulations and reporting requirements governing US investment advisors and asset managers, recent amendments to federal rules will impact how family...more

Names Rule Amendments Will Require Changes For Certain Funds

On September 20, 2023, in a 4-1 vote, the US Securities and Exchange Commission (SEC) adopted amendments (the Amendments) to the rule governing fund names, which impose new disclosure, compliance, reporting, and recordkeeping...more

SEC Adopts New Private Fund Adviser Rules with Nuanced Application to Non-US Advisers

The US Securities and Exchange Commission (SEC) recently adopted sweeping new rules under the Investment Advisers Act of 1940 (Advisers Act) that apply in certain circumstances to non-US advisers to private investment funds....more

Split SEC Adopts New and Amended Rules Overhauling Private Fund Industry

On August 23, 2023, the US Securities and Exchange Commission (SEC) voted 3-2 to adopt new and amended rules under the Investment Advisers Act of 1940, as amended (Advisers Act) that will impose additional requirements on...more

SEC Proposes Sweeping Rules on Broker-Dealer and Investment Adviser Technology Use

The US Securities and Exchange Commission (SEC) proposed on July 26, 2023 new rules designed to address conflicts of interest from the use of predictive data analytics in “investor interactions” by broker-dealers and...more

Current Developments in SEC Examinations & Enforcement: A Special Report for Private Funds 2022-2023

Private funds were a major focus of the US Securities and Exchange Commission’s (SEC’s or Commission’s) enforcement and rulemaking programs in 2022, and we expect 2023 to be even more active. The Division of Examinations’...more

ETF Roundup – Issue 7 December 2021

UPDATE ON CRYPTO ASSETS IN ETFS - In 2018, the US Securities and Exchange Commission’s Division of Investment Management staff penned a letter to the Investment Company Institute and the Securities Industry and Financial...more

SEC Examination Staff Outlines Observations of Registered Fund Compliance Risks

The Division of Examinations staff of the US Securities and Exchange Commission (SEC) published a risk alert on October 26, 2021, titled “Observations from Examinations in the Registered Investment Company Initiatives,” which...more

Tax Proposals May Affect Exchange-Traded Funds

Recently proposed tax legislation, if enacted, would fundamentally alter the taxation of exchange‑traded funds. This LawFlash discusses the potential consequences of such legislation on industry participants, including retail...more

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