On April 4, 2025, the CFTC's Division of Market Participants issued No-Action Letter 25-09 regarding the controversial Pre-Trade Mid-Market Mark ("PTMMM") requirements in CFTC Regulation 23.431, effectively eliminating the...more
4/17/2025
/ CFTC ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Markets ,
Financial Services Industry ,
Market Participants ,
No-Action Letters ,
Penalties ,
Regulatory Reform ,
Regulatory Requirements ,
Swap Dealers
On March 19, 2025, the SEC made two significant updates to the Marketing Rule's FAQ page. DWT discussed the SEC's recently adopted Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940) in our 2024 post, and...more
The use of artificial intelligence and machine learning technology solutions ("AI") is becoming increasingly common in all industries, including the registered investment adviser ("RIA") space. A recent survey by AI platform...more
5/6/2024
/ Artificial Intelligence ,
Automation Systems ,
Broker-Dealer ,
Compliance ,
Disclosure Requirements ,
Enforcement ,
Fraud ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Machine Learning ,
Portfolio Managers ,
Securities and Exchange Commission (SEC)
Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more
1/19/2024
/ Compliance ,
Conflicts of Interest ,
Cryptoassets ,
Cryptocurrency ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement Actions ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Marketing ,
Policies and Procedures ,
Private Funds ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
On May 3, 2023, the Commission announced that it adopted amendments to two rules enhancing disclosure requirements for share repurchases and private fund reporting. First, the Commission adopted amendments to the rules on...more