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Form BE-180 Deadline Is Fast Approaching For Electronic Filers, Including Private Fund Managers

The Bureau of Economic Analysis’ (BEA) 2019 benchmark survey1 of financial services transactions between U.S. financial services providers and foreign persons is due on October 30, 2020, for respondents who submit their form...more

SEC Updates Regulatory Framework For Fund Of Funds Arrangements, But Private Funds Remain Subject To Limits On Purchases Of...

What You Need To Know: •The SEC’s updates to the regulatory framework for fund of funds arrangements will be helpful to registered investment companies. •Private funds will not be afforded additional flexibility to invest...more

SEC Proposes Conditional Broker Exemption For Finders

What You Need To Know: •The SEC proposes to exempt two types of Finders from broker-dealer registration pursuant if they satisfy certain conditions. •Tier I Finders may provide potential investors’ contact information to...more

SEC Expands The Accredited Investor Definition

On August 26, 2020, the Securities and Exchange Commission (SEC) adopted amendments (the Amendment) to the “accredited investor” definition to broaden the category of potential investors in private offerings of securities...more

SEC Proposes To Amend Form 13F Reporting Thresholds For Institutional Investment Managers

On July 10, 2020, the Securities and Exchange Commission (SEC) proposed to raise the Form 13F reporting threshold for institutional investment managers from $100 million to $3.5 billion (the Proposal). Currently, investment...more

OCIE Risk Alert: Key Takeaways And Practical Applications For Hedge Fund Managers

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert entitled Observations from Examinations of Investment Advisers Managing Private Funds (the “Alert”). The...more

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