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Raising the Bar: SEC Evaluating an Increase in Minimum AUM Threshold for Investment Adviser Registration

On April 8, 2025, Acting SEC Chairman Mark T. Uyeda gave a speech signaling that the SEC may revisit the current minimum assets under management (“AUM”) threshold for federal registration, potentially reducing the number of...more

The SEC Under Paul Atkins – What to Expect for Registered and Private Offerings, Climate-Related Disclosure, Consolidated Audit...

Paul Atkins, who has been nominated by President Trump to serve as Chairperson of the Securities & Exchange Commission, last week completed a short confirmation hearing before the U.S. Senate Banking Committee. Despite its...more

Confirmation Hearing for SEC Chair Nominee Atkins — Takeaways for Fund Managers

The Senate Banking Committee convened on Thursday to consider the nomination of Paul Atkins, President Trump’s nominee for Chair of the Securities and Exchange Commission, along with the nominees for the Comptroller of the...more

New Interim Rule Removes CTA Reporting Requirements for U.S. Companies and U.S. Persons

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership...more

Top Ten Regulatory and Litigation Risks for Private Funds in 2024

To understand the litigation and regulatory risks that are coming in 2024 for private capital, it is helpful to look back briefly on recent events. Arguably, the single most important event over the last 18 months was the...more

SEC Proposes ESG Reporting and Disclosure Requirements for Private Fund Advisers

On May 25, the Securities and Exchange Commission (“SEC”) issued proposed rules under the Investment Advisers Act of 1940 (“Advisers Act”) for advisers to private funds that consider environmental, social or governance...more

SEC Reopens Comment Period for Proposed Private Fund Adviser Rules

Monday, the U.S. Securities and Exchange Commission (“SEC”) announced that it will reopen the public comment period on its proposed rules relating to private fund advisers. The comment period will now remain open until 30...more

Conflicts of Interest: How High Will the Bar be Raised?

The SEC last month proposed rules under the Advisers Act indicating a dramatic shift in how the SEC intends to reduce conflicts of interest involving private fund managers and their investors. As we previously noted in the...more

In A Trinity of Releases, the SEC Proposes To Make Hedging Transactions More Transparent

If adopted, the proposals will likely impact market practices - In a trinity of proposing releases rolled out in less than three months, the SEC has comprehensively proposed to regulate the use of derivatives and short...more

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