In its most simple form, a net asset value-based facility (“NAV Facility”) is a credit facility, whereby availability under the facility is based on the net asset value of the portfolio investments of the borrower, often a...more
On March 24, 2023, Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, released its guidance materials on its final rule (the “Rule”) establishing beneficial ownership information...more
On June 17, 2021, the SEC issued an order (the “Order”) to adjust for inflation the dollar amount thresholds that determine when an investor is a “qualified client” under Rule 205-3 of the Investment Advisers Act of 1940, as...more
On January 7, 2020, the Securities and Exchange Commission (“SEC”) issued its 2020 Examination Priorities, a yearly publication highlighting new and existing areas of focus for the Office of Compliance Inspections and...more
1/16/2020
/ Anti-Money Laundering ,
Broker-Dealer ,
Cybersecurity ,
Financial Industry Regulatory Authority (FINRA) ,
FinTech ,
Form CRS ,
Investment Adviser ,
OCIE ,
Regulation Best Interest ,
Retail Investors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Standard of Care
In recent years, improving the protection of retail investors has been a main focus of the Securities and Exchange Commission (“SEC”). On October 26, 2017, Stephanie Avakian, co-director of the Division of Enforcement,...more
In recent years, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) has been paying close attention to the fees and expenses charged by private funds and their...more