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New Marketing Rule FAQs Facilitate Compliance on Net Performance

On March 19, 2025, the SEC Staff published two Marketing Rule FAQs that address some of the more challenging aspects of the Marketing Rule requirement to present net performance information. Specifically, the FAQs provide a...more

SEC Adopts Private Fund Reform Rules

On August 23, 2023, in a 3-2 vote, the SEC adopted a rule package (the “Adopted Rules”) that establishes significant new obligations for private fund advisers under the Investment Advisers Act of 1940. While the Adopted...more

SEC Adopts Amendments to Form PF; Establishes Certain “Event Reporting” Requirements for Private Equity Advisers and Large Hedge...

On May 3, 2023, the SEC adopted amendments to Form PF that will establish new event-reporting requirements for “private equity fund advisers” and “large hedge fund advisers”, and will require certain additional annual...more

SEC Staff Addresses Net Performance Presentation Requirements for Single Investments Under Marketing Rule

On January 11, 2023, the SEC Staff published a question-and-answer in its Marketing Compliance FAQs that addresses whether an advertisement that includes gross performance information for a single investment (or group of...more

SEC Proposes RIA Outsourcing Rule

On October 26, the SEC proposed a new Advisers Act rule (the “Proposed Rule”) that would establish specific obligations for Registered Investment Advisers with respect to outsourcing of “Covered Functions”, as that term is...more

SEC Investment Adviser Marketing Rule: Compliance Date is Nov. 4, 2022

In late 2020, the SEC adopted1 rule amendments that require SECregistered investment advisers to, by November 4, 2022, switch their compliance regimes from the SEC’s current Advertising and Cash Solicitation Rules (Rules...more

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