On December 22, 2020, the Securities and Exchange Commission announced it had finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors....more
A registered investment adviser (RIA) that has “custody” of client funds or securities must comply with the provisions of Rule 206(4)-2 under the Investment Advisers Act of 1940 (Rule), including those related to the use of a...more
On November 4, 2019, the Office of the Chief Counsel of the SEC's Division of Investment Management extended the temporary no-action relief from compliance with the registration and other provisions of the Investment Advisers...more
On September 4, 2019, the SEC's Office of Compliance Inspections and Examinations (OCIE) released a new risk alert on certain principal and agency cross trading compliance issues identified in deficiency letters in connection...more
REGULATORY UPDATES - Investors Continue to Press Regulators for Disclosure of Environmental, Social, and Governance (“ESG”) Risks...more
As part of its ongoing examination of the Custody Rule, the SEC’s Division of Investment Management is seeking views from the securities industry members and the public on two issues regarding the Custody Rule: (1) the...more
The staff of the Division of Investment Management (Staff) of the U.S. Securities and Exchange Commission (SEC) published a Guidance Update (Guidance) on February 23, 2017, on the subject of automated investment advisers...more
On April 25, 2016, the Staff of the Division of Investment Management of the Securities and Exchange Commission issued a no-action letter that provides that it would not recommend enforcement action to the Commission under...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
How should fund directors monitor gifts and entertainment received by investment adviser personnel? This question moved to the forefront in February, when the Securities and Exchange Commission’s Division of Investment...more