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Newly Proposed Rule Expanding Cyber Incident Reporting to Affect Financial Services Companies

Recently, the US Department of Homeland Security’s (DHS) Cybersecurity & Infrastructure Security Agency (CISA) issued a notice of proposed rulemaking (NPRM) which, if adopted, would require “covered entities” of critical...more

Fifth Circuit Vacates SEC Private Fund Advisers Rule

On June 5, the US Court of Appeals for the Fifth Circuit vacated a US Securities and Exchange Commission (SEC) Rule designed to provide investors in private funds — such as private equity, private credit, hedge funds, venture...more

Four Months Out: Private Fund Advisors Prepare for September Compliance Deadline Amidst Challenge in the Fifth Circuit

In September 2023, we covered the Rules (Rule) published by the US Securities and Exchange Commission (SEC), developed to promote transparency for investors by increasing visibility into compensation schemes, sales practices,...more

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

Significant New Private Fund Rules Adopted by SEC

On August 23, 2023, in its efforts to promote transparency for investors by increasing visibility into compensation schemes, sales practices, and conflicts of interest, the US Securities and Exchange Commission (SEC) adopted...more

10 Legal Challenges for the Cannabis Industry in 2023

1. Cannabis Entering the Metaverse - As we discuss in greater detail here, the Metaverse provides expansive marketing and sales opportunities for cannabis companies due to its decentralized nature and the varied regulatory...more

SEC Proposes Safeguarding Rule Amending Custody Rule

The US Securities and Exchange Commission (SEC) released a proposal to amend Rule 206(4)-2, the “custody rule” (the “current rule”), which currently requires all investment advisors with the ability to possess client funds...more

2023 Priorities for SEC Division of Examinations

The US Securities and Exchange Commission (SEC) Division of Examinations recently released its 2023 Examinations Priorities, a yearly report that provides insight into the Division’s areas of focus to improve compliance,...more

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