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SEC Updates Marketing Rule and Form PF FAQs in Short Succession

On March 19, the SEC issued updates to its FAQs regarding compliance with Rule 206(4)-1 of the Advisers Act (the Marketing Rule) addressing (i) when gross and net performance are required for certain “extracted” performance,...more

ILPA Releases New Reporting and Performance Templates

On January 22, the Institutional Limited Partners Association (ILPA) released an update to its 2016 Reporting Template and unveiled a new Performance Template. Together, the goal of these documents is to enhance and...more

Court Pauses Beneficial Ownership Reporting Under the Corporate Transparency Act

On December 3, 2024, the District Court for the Eastern District of Texas issued an order implementing a nationwide preliminary injunction of the Corporate Transparency Act and its enforcement. The court also stayed the...more

FinCEN Throws Another Curveball: Beneficial Ownership Reporting for Dissolved Companies

This week, FinCEN issued new FAQs interpreting the obligations of the Corporate Transparency Act (“CTA”) that would require entities that were dissolved prior to the due date of the beneficial ownership initial report (“BOI...more

SEC Adopts Amendments To Regulation S-P

On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

Updated FinCEN CTA Guidance Impacts Private Equity Funds

On January 12, 2024, FinCEN updated its interpretations of the Corporate Transparency Act (“CTA”) that potentially will have a significant impact on private equity firms. This alert provides an overview of the CTA and certain...more

SEC Adopts Updates to Private Fund Reporting on Form PF

On May 3, 2023, the SEC approved amendments to Form PF reporting requirements for private fund managers. Most significantly, the updates introduce new event reporting obligations for SEC-registered private fund advisers,...more

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