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SEC Staff Updates FAQs Regarding Marketing Rule Compliance – Gross and Net Performance

On March 19, 2025, the staff of the Division of Investment Management (the “SEC Staff”) of the Securities and Exchange Commission (the “SEC”) released an update to its Frequently Asked Questions1 (the “FAQs”) relating to...more

Upcoming Reminders for FinCEN Beneficial Ownership Information Reporting

The Financial Crimes Enforcement Network’s (“FinCEN’s”) beneficial ownership reporting rule, issued under the Corporate Transparency Act (the “CTA” and such rule, the “BOI Reporting Rule”) became effective as of January 1,...more

Multi-Strat Funds: Structuring Considerations

In a typical multi-strategy fund (“Multi-Strat”), a fund structure is established by an investment manager (the “Investment Manager”) that runs multiple investment strategy portfolios within it, oftentimes with different...more

Seward & Kissel Releases 2023 Established Manager Hedge Fund Study

The 2023 Seward & Kissel Established Manager Hedge Fund Study (the “Study”) focuses on those Seward & Kissel investment manager clients that have been in business for at least 5 years and manage greater than $1 billion in...more

August 30 Deadline for TIC Form SHL

Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

The Rise of the Pass-Through Expense Model

While the concept of a pass-through expense model is most often associated with multi-strategy alternative investment funds, this expense structure is beginning to gain wider traction among other managers as well, depending...more

SEC Adopts Gross Short Position and Activity Reporting by Institutional Investment Managers

On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted new Rule 13f-2 (the “New Rule”) under Section 13(f)(2) of the Securities Exchange Act of 1934 (the “Exchange Act”), as well as related Form SHO....more

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