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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'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

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

SEC and CFTC Adopt Amendments to Form PF for Increased Disclosure

Brief Overview - On 8 February 2024, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF (the Amendments), the confidential reporting form...more

The SEC's New Private Fund Adviser Rules: A Guide to Compliance (Updated)

On 23 August, the US Securities and Exchange Commission adopted new rules and rule amendments that will impose substantial regulation on the management and operation of private funds by investment advisers. The Guide to...more

The SEC's New Private Fund Adviser Rules: A Guide to Compliance

On 23 August, the US Securities and Exchange Commission adopted new rules and rule amendments that will impose substantial regulation on the management and operation of private funds by investment advisers. The Guide to...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

The SEC Significantly Expands the Scope of Form PF Reporting

Introduction and Summary - On 3 May 2023, the Securities and Exchange Commission (SEC) approved amendments to Form PF (the Amendments), the confidential reporting form required to be filed by certain SEC-registered private...more

Registered Funds and the New ESG Rule Proposals: Everything You Wanted to Know (But Were Afraid to Ask)

EXECUTIVE SUMMARY - On 25 May 2022, the Securities and Exchange Commission (SEC) proposed a series of amendments (the Proposed Amendments) to rules and reporting forms, which purport to provide investors with additional...more

SEC Increases the "Qualified Client" Net Worth and Assets Under Management Thresholds

INTRODUCTION - On 17 June 2021, the U.S. Securities and Exchange Commission (the SEC) issued an order to: (i) increase the net worth threshold for “qualified clients” under Rule 205-3 of the Investment Advisers Act of 1940,...more

The SEC's Modernized Marketing Rule for Investment Advisers

On 22 December 2020, the U.S. Securities and Exchange Commission (SEC) adopted amendments (the final rule) to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the Advisers Act) to modernize the regulation of...more

Finders Keepers? SEC Proposes Exemption from Broker-Dealer Registration for Finders in Private Placements, but Questions Remain

OVERVIEW - On October 7, 2020, the U.S. Securities and Exchange Commission (SEC) proposed a conditional exemption, operating as a nonexclusive safe harbor from the broker registration requirements of Section 15(a) of the...more

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