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Updated SEC Marketing Rule FAQ: Clarification Regarding Presentation of Net Extracted Performance

On March 19, 2025, the Securities and Exchange Commission (SEC) staff issued an update to its frequently asked questions (FAQ) guidance with respect to registered investment advisers’ compliance with Rule 206(4)-1 (Marketing...more

SEC Adopts New Private Funds Rules: Key Takeaways for Private Fund Advisers and Investors

During an open meeting on Wednesday, August 23, 2023, the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) voted 3-2 along party lines to adopt new rules (collectively referred to as the “Private Funds...more

The SEC Renews its Emphasis on Compliance with the New Marketing Rule

On June 8, 2023, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“Division”) released a risk alert (the “Risk Alert”) outlining the SEC’s broadened examination priorities with respect to revised...more

Presentation and Portability of Investment Adviser Performance

An investment adviser’s investment track record is an important resource when raising capital from prospective investors. However, investment advisers, particularly registered investment advisers or emerging fund managers,...more

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