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Fifth Circuit Vacates the Private Funds Rules And Constrains the SEC’s Rulemaking Authority

Yesterday, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit vacated the “Private Funds Rules,” which the Securities and Exchange Commission (the “SEC”) adopted on August 23, 2023. The opinion of the...more

Key Questions for the Upcoming Private Funds Rules Fifth Circuit Decision

As a reminder, the Securities and Exchange Commission (SEC) and the National Association of Private Fund Managers (NAPFM) and the other Petitioners in the Private Funds Rules Litigation1 requested that the three-judge panel...more

Reviewing the Industry Groups’ Opening Brief Challenging the Private Funds Rules

On November 1, 2023, the industry groups (the Petitioners) challenging the new Private Fund Adviser Rules filed in the US Court of Appeals for the Fifth Circuit their opening brief (the Brief) setting forth their legal...more

SEC Files First Enforcement Complaint Under Liquidity Rule

On May 5, 2023, the U.S. Securities & Exchange Commission filed its first enforcement complaint under Rule 22e-4 of the Investment Company Act of 1940, 17 C.F.R. § 270.22e-4 (the Liquidity Rule). The complaint was brought...more

SEC Enforcement Weighs in on Variable Annuity Exchanges for the First Time

After years of relative silence related to variable annuity exchanges on the regulatory front, the U.S. Securities and Exchange Commission announced last week settled charges against RiverSource Distributors, Inc...more

Lawsuits Targeting SPACs as Unregistered Investment Companies

Within the last two weeks, a group of plaintiffs’ attorneys have filed derivative lawsuits in U.S. federal court in New York against three separate special purpose acquisition companies (“SPACs”) — Pershing Square Tontine...more

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