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Final Rules Investment Management

Seward & Kissel LLP

SEC Extends Effective and Compliance Dates for Amendments to Investment Company Reporting Requirements

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Compliance Officers - Quick Take: The SEC announced a two-year extension to the effective and compliance dates for rule amendments...more

Mayer Brown Free Writings + Perspectives

House Financial Services Committee Urges SEC Withdrawal of 14 Proposed and Final Rules

On March 31, 2025, the U.S. House Financial Services Committee (Committee) penned a letter to acting Securities and Exchange Commission (SEC) Chair Mark Uyeda identifying 14 proposed and final rules that, according to the...more

K&L Gates LLP

United States: House Committee on Financial Services Urges the SEC to Withdraw Final and Proposed Rules

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On 31 March 2025, the House Committee on Financial Services (Committee), in a letter to Acting Chairman of the US Securities and Exchange Commission (SEC), Mark Uyeda, identified a series of proposed and adopted rules that...more

Vedder Price

SEC Grants One-Year Exemption from New Short Sale Reporting Requirements

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On February 7, 2025, the SEC issued a one-year exemption from compliance with new Rule 13f‑2 under the Securities Exchange Act of 1934 and related reporting on new Form SHO. The SEC adopted Rule 13f-2 and the Form SHO...more

Katten Muchin Rosenman LLP

SEC Extends Compliance Dates for the 'Names Rule' Amendments

On March 14, 2025, the Securities and Exchange Commission (SEC) issued the following press release (Release) to extend compliance with the amendments (Amendments) to Rule 35d-1 (Names Rule) under the Investment Company Act of...more

Mayer Brown Free Writings + Perspectives

SEC Grants Temporary Exemption from Rule 13f-2 and Form SHO Compliance

On February 7, 2025, the US Securities and Exchange Commission (SEC) provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and the associated Form SHO reporting. Originally, the...more

Mayer Brown Free Writings + Perspectives

The Rules of the Name: SEC Staff Updates Guidance on Fund Naming Rules

The Securities and Exchange Commission (SEC) staff issued updated FAQs regarding Rule 35d-1 under the Investment Company Act of 1940 (the “Names Rule”) on January 8, 2025.  These updates reflect amendments that were adopted...more

Carlton Fields

Amendments to N-PORT May Be OUT-Ported New SEC Reporting Requirements Already Under Challenge

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Gary Gensler’s tenure as SEC chair can be remembered for an impressive number of rule proposals, many of which encountered vehement industry opposition or were challenged in court, struck down, or stayed....more

K&L Gates LLP

SEC Updates Names Rule FAQs

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On 8 January 2025, the staff of the Division of Investment Management of the US Securities and Exchange Commission (the SEC) released an updated set of Frequently Asked Questions (the FAQs) related to the amendments to Rule...more

Mayer Brown Free Writings + Perspectives

SEC Abandons Review of Vacated Private Fund Adviser Rules

The Securities and Exchange Commission let pass the deadline to seek a review of the decision by the US Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) to vacate the SEC’s final rule relating to private fund...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

DarrowEverett LLP

Fifth Circuit Puts the Brakes on SEC’s Private Fund Rules: What’s Next For Private Fund Advisers

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In a continuation of recent court decisions overturning the rulemaking authority of federal agencies, a recent decision by the U.S. Court of Appeals for the Fifth Circuit vacated the Securities and Exchange Commission’s (SEC)...more

A&O Shearman

SEC private fund adviser rule vacated by Fifth Circuit

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On June 5, 2024, the U.S. Court of Appeals for the Fifth Circuit held that the U.S. Securities and Exchange Commission had exceeded its statutory authority in adopting its controversial private fund advisers rule....more

Sullivan & Worcester

Are the SEC’s Private Fund Advisers Rules Now Dead? No, but they are on Life Support

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The U.S. Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) has thrown a wrench into the gears of the U.S. Securities and Exchange Commission (the “SEC”) in its attempt to regulate those investment advisers that...more

Mayer Brown

Fifth Circuit Vacates Private Fund Adviser Rules

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On June 5, 2024, a three-judge panel of the Fifth Circuit Court of Appeals (the “Fifth Circuit”) unanimously vacated the rule adopted by the US Securities and Exchange Commission (the “SEC”) to enhance the regulation of...more

Bricker Graydon LLP

DOL Fiduciary Investment Advice - We Have Tread This Road Before, Has Anything Changed for Advisors?

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The Department of Labor (DOL) recently released the Retirement Security Rule - yet another iteration of its updated fiduciary rule that has been kicking around the agency for over a decade....more

Hinckley Allen

SEC Adopts Amendments to the Internet Adviser Exemption

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On March 27, 2024, the Securities and Exchange Commission (“SEC”) adopted a final rule (the “Final Rule”) amending SEC Rule 203A-1(E) (the “Internet Adviser Exemption”) promulgated under the Investment Advisers Act of 1940,...more

DarrowEverett LLP

SEC’s New Rules Give SPACs, Target Companies Much to Consider

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On January 24, 2024, the U.S. Securities and Exchange Commission (the “SEC”) adopted new final rules relating to special purpose acquisition companies (“SPACs”). The new rules affect both initial public offerings (“IPOs”) for...more

Troutman Pepper Locke

Amendments and Clarifications to the Small Business Investment Company Investment Diversification and Growth Rules

Troutman Pepper Locke on

On January 19, the U.S. Small Business Administration (SBA) published a direct and final rule (the rule), including substantive and technical amendments and clarifications to the Small Business Investment Company Investment...more

Paul Hastings LLP

SEC Adopts Rules Enhancing Short Sale Disclosures

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On October 13, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted final rules requiring the reporting and disclosure of short sale trade data information. New Rule 13f-2 implements new obligations on...more

Proskauer Rose LLP

Special DOL Proxy Voting Rule Set to Take Effect on December 1, 2023 – Potential Action Items for ERISA Fiduciary Investment...

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In late 2022, the U.S. Department of Labor (the “DOL”) issued final regulations (the “Final Rules”) which address the extent to which ERISA fiduciaries may consider environmental, social and governance (“ESG”) factors when...more

Nossaman LLP

Federal Court Rejects States’ Challenge to DOL’s ESG Investing Rule

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On September 21, 2023, a federal judge in Texas granted summary judgment in, and thus dismissed, a lawsuit filed by the Attorneys General of 25 states and other interested parties challenging a final rule issued by the U.S....more

Nelson Mullins Riley & Scarborough LLP

SEC Adopts Its New Private Funds Adviser Rules - Final Rules Create New Requirements for Private Fund Advisers

The U.S. Securities and Exchange Commission (the “SEC”) adopted and published its Final Rule Release IA-6383 under the Investment Advisers Act of 1940 (the “Advisers Act”) on August 23, 2023. These rules (the “Final Rules”)...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Practical Guide to Interpreting the New SEC Private Fund Adviser Rules

On August 23, 2023, the Securities and Exchange Commission (the SEC) voted 3-2 to adopt a final set of rules and amendments under the Investment Advisers Act of 1940 (collectively, the Final Rules) that significantly expand...more

White & Case LLP

SEC Adopts Final Private Fund Adviser Rules

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New rules are expected to have substantial impact on funds industry - On August 23, 2023, the Securities and Exchange Commission ("SEC") approved significant new rules applicable to advisers of private funds (the "Private...more

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