On August 23, 2023, the Securities and Exchange Commission (the “SEC”) adopted new rules and rule amendments (collectively, the “Rules”) under the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”)...more
In the client alert dated January 27, 2023, we described a recently enacted federal exemption (the “Exemption”) from SEC registration for Merger and Acquisition Brokers which meet the qualifications of amended Section 15(b)...more
Section 15(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) requires registration with the Securities and Exchange Commission (the “SEC”) of securities brokers, which is defined as “any person engaged in the...more
On June 28, 2016, the Securities and Exchange Commission ("SEC") issued a proposed rule (Rule 206(4)-4, with proposed amendments to Rule 204-2) which would require SEC-registered investment advisers to adopt and implement...more
The Securities and Exchange Commission ("SEC") is becoming increasingly concerned with cybersecurity risks to which investment advisers may be exposed. Consequently, it has recently issued guidance ("Guidance") as to actions...more
In November 2012, the CFTC's Division of Swap Dealer and Intermediary Oversight issued a no-action letter stating that the Division would not recommend that the CFTC take enforcement action against a family office for failure...more
On July 10, 2013, the SEC took the following actions that are likely to have a significant impact on hedge funds, private investment funds and other companies that raise capital through private offerings of securities...more
7/16/2013
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General Solicitation ,
Hedge Funds ,
IRS ,
JOBS Act ,
Private Investment Funds ,
Private Placements ,
Regulation D ,
Rule 144A ,
Rule 506 Offerings ,
Securities and Exchange Commission (SEC)
As noted in an earlier Client bulletin, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter dated November 29, 2012 enabling...more