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Who Needs Customers, Anyway? New SEC Rules Turn Traders Into Dealers

The Securities and Exchange Commission (the "SEC" or "Commission") has adopted new rules that further define the phrase "part of a regular business" for purposes of determining whether a person is a "dealer" or "government...more

SEC Adopts Long-Awaited and Heavily Debated Private Fund Adviser Rules

The U.S. Securities and Exchange Commission ("SEC") adopted multiple rules that will impact private funds, governing documents, and side letters....more

SEC Highlights Compliance With New Advertising Rule

The Securities and Exchange Commission ("SEC") recently reminded SEC registered investment advisers of the upcoming compliance date (November 4, 2022) for the revised investment adviser advertising rule, and provided a list...more

SEC's Proposed Rules Target Advisers to Private Funds

On February 9, 2022, the SEC proposed new rules focused on private fund advisers' practices, reporting, and disclosures ("Proposed Rules"). The Proposed Rules would apply to all SEC registered advisers to private funds, and a...more

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