On March 12, 2025, the staff of the Securities and Exchange Commission (“SEC”) issued no-action guidance providing that certain minimum investment amounts, along with certain written representations from the purchaser, could...more
On March 19, 2025, the Securities and Exchange Commission (“SEC”) updated its frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). The new FAQs permit...more
On February 8, 2024, the SEC adopted its third set of amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. The amendments specifically affect Sections 1 and 2...more
In a 3-0 decision, the Fifth Circuit Court of Appeals vacated the SEC’s private fund adviser rules (“Final Rule”). Each component of the Final Rule was vacated, including the Private Fund Audit Rule, Private Fund Quarterly...more
A divided SEC adopted numerous reforms for private fund managers on August 23, 2023. These reforms represent the largest regulatory change for private fund managers since Dodd-Frank. The SEC’s stated purpose is to bring...more
On April 7, 2020, the Securities and Exchange Commission’s (the “SEC” or the “Staff”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide SEC-registered broker-dealers and investment...more
On April 27, 2020, the staff of the Securities and Exchange Commission (the “SEC”) updated its Division of Investment Management Coronavirus (COVID-19) Response FAQs and Staff Responses to Questions About the Custody Rule...more
In light of the COVID-19 pandemic, many federally registered investment advisers have moved to temporary remote working arrangements. As a result of these temporary offices, advisers are faced with registration and licensing...more
On March 13, 2020, the Securities and Exchange Commission (“SEC”) issued an exemptive order providing temporary relief from Form ADV and Form PF filing obligations applicable to registered investment advisers and...more
On March 13, 2020, the staff of the Securities and Exchange Commission (“SEC”) issued an exemptive order providing relief from certain provisions of the Investment Company Act of 1940, as amended (the “1940 Act”), to...more
3/17/2020
/ Coronavirus/COVID-19 ,
Corporate Governance ,
Disclosure Requirements ,
Emergency Response ,
Exemptive Relief ,
Filing Requirements ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Funds ,
Notice Requirements ,
Prospectus ,
Securities and Exchange Commission (SEC) ,
Virtual Meetings
Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) or with a state, as well as commodity pool operators and commodity trading advisors registered with the U.S. Commodity Futures Trading...more
2/11/2020
/ CFTC ,
Chief Compliance Officers ,
Commodity Trading Advisors (CTAs) ,
Compliance ,
CPO ,
Filing Deadlines ,
Filing Requirements ,
Investment Adviser ,
Private Investment Funds ,
Required Forms ,
Securities and Exchange Commission (SEC)
Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more
2/16/2018
/ Commodity Trading Advisors (CTAs) ,
CPOs ,
Data Collection ,
Disclosure Requirements ,
FATCA ,
FBAR ,
Filing Deadlines ,
Filing Requirements ,
Financial Institutions ,
FinCEN ,
Foreign Direct Investment ,
Foreign Financial Accounts ,
Form ADV ,
Investment Adviser ,
Private Funds ,
Registration ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury