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United States: House Committee on Financial Services Urges the SEC to Withdraw Final and Proposed Rules

On 31 March 2025, the House Committee on Financial Services (Committee), in a letter to Acting Chairman of the US Securities and Exchange Commission (SEC), Mark Uyeda, identified a series of proposed and adopted rules that...more

SEC Marketing Rule FAQs Yield New Guidance

On 19 March 2025, the Securities and Exchange Commission staff issued updated frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the Marketing Rule) (available here)....more

SEC Extends Compliance Period for the Amended Names Rule

On 14 March 2025, the Securities Exchange Commission (SEC) extended the compliance dates for the amendments to Rule 35d-1 (Amended Names Rule) under the Investment Company Act of 1940, as amended (1940 Act), by six months....more

United States: SEC Issues New Guidance on Schedule 13G Eligibility

The SEC’s Division of Corporation Finance recently issued new guidance regarding when shareholders can file beneficial ownership reports on Schedule 13G. While the 11 February 2025 Compliance and Disclosure Interpretation...more

United States: Unsustainable—Acting SEC Chairman Signals Reconsideration of Climate Risk Disclosure Rules

In March 2024, the SEC adopted The Enhancement and Standardization of Climate-Related Disclosures for Investors final rule, which required companies to make disclosures regarding climate risks and disclosures of Scope 1 and 2...more

Asset Management Regulatory Year in Review 2024

2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more

SEC Updates Names Rule FAQs

On 8 January 2025, the staff of the Division of Investment Management of the US Securities and Exchange Commission (the SEC) released an updated set of Frequently Asked Questions (the FAQs) related to the amendments to Rule...more

SEC's Division of Examinations Halloween Treat–2025 Priorities

In order to discourage investment advisers, broker-dealers and investment companies from engaging in any “tricks,” the SEC’s Division of Examinations has published a treat, in the form of its 2025 Examination Priorities (the...more

SEC Initiates Sweep of Adviser on T+1 Compliance

Over the last week, several registered investment advisers have received examination letters, issued from both the Securities and Exchange Commission’s national office in Washington, D.C., and from at least one regional...more

The SEC Fines Stand-Alone Adviser for Off-Channel Communications

Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more

Threading the Needle: The US Securities and Exchange Commission's Final Climate-Related Disclosure Rules

On 6 March 2023, by a 3-2 vote of the Commissioners split along party lines, the US Securities and Exchange Commission (SEC) adopted “The Enhancement and Standardization of Climate-Related Disclosures for Investors” final...more

Global Survey of ESG Regulations for Asset Managers

Asset managers (i.e., investment advisers) offering funds in more than one country are accustomed to adapting to different regulatory requirements. However, the challenges presented by the global regulation of environmental,...more

Stay on Target: FINRA Proposes Rules Permitting Presentation of Performance Projections and Targets

The regulation of broker-dealer communications is delegated to the Financial Industry Regulatory Authority, Inc. (FINRA), while investment adviser advertisements are regulated directly by the US Securities and Exchange...more

Global Survey of ESG Regulations for Asset Managers - ESG and the Sustainable Economy Handbook

Investment advisers offering funds in more than one country are accustomed to adapting to different regulatory requirements. However, the challenges presented by the global regulation of environmental, social, and governance...more

T-218 Until T+1: Considerations for Investment Advisers

On 28 May 2024, the settlement period for substantially all transactions in US markets will be reduced by one day, from two business days after the trade date (T+2) to one business day after the trade date (T+1). While most...more

Hypothetical Performance Crackdown: Nine Firms Charged With Violations of Investment Adviser Marketing and Recordkeeping Rules

On 11 September 2023, the Securities and Exchange Commission (SEC) announced charges against nine investment advisers for violations of: (i) the hypothetical performance requirements set forth in Advisers Act Rule 206(4)-1...more

Road Map for an Examination: SEC Examination Risk Alert Lays Out SEC Examination Strategy Considerations

For registered investment advisers, examinations by the Securities and Exchange Commission (SEC) are a part of doing business. While an SEC examination is inevitable, many advisers have often wondered why they were selected...more

2023 ESG State Legislation Wrap Up

In January of 2021, Senate Bill 2291 was introduced into the North Dakota state senate. It was considered, adopted, and signed into law three months later in March of 2021. This bill was the first of what would become scores...more

The ESG Debate Heats Up: State AGs Investigating Asset Manager Involvement in ESG Initiatives and Related Proxy Voting

Over the past two weeks, multiple state attorneys general have sent civil investigative demands (CIDs) or subpoenas to asset managers regarding their involvement in the environmental, social, and governance (ESG) initiatives...more

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