On March 19, the SEC issued updates to its FAQs regarding compliance with Rule 206(4)-1 of the Advisers Act (the Marketing Rule) addressing (i) when gross and net performance are required for certain “extracted” performance,...more
The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more
On February 8, 2024, the SEC adopted its third set of amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. The amendments specifically affect Sections 1 and 2...more
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have extended the compliance deadline for the amendments to Form PF, moving it from March 12, 2025 to June 12, 2025....more
On January 29, 2025, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (together, the “Agencies”) jointly announced that the compliance date for the new Form PF would be extended by three...more
As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more
In February 2024, the SEC and the Commodity Futures Trading Commission (CFTC) adopted major amendments to Form PF to provide greater transparency into the operations and strategies of private funds, and to assist the...more
The latest round of revisions to Form PF made a stealthy arrival, with the SEC announcing in mid-February that it adopted the updates without an in-person vote. As the third set of amendments to Form PF in the past 12...more
On February 8, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC and, together with the SEC, the Commissions) voted to adopt amendments to Form PF1 that will impact the...more
At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more
On February 8, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF, the confidential reporting form for certain registered investment advisers to...more
This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers. Please contact us with any questions on the topics covered below. The SEC Adopts Significant New Rules for Private...more
On July 12, 2023, in a 3-2 vote, the SEC adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, representing the SEC’s latest reforms of the rules governing money market funds in its effort to improve their...more
REGULATORY UPDATES - Recent SEC Leadership Changes - The Securities and Exchange Commission (the “SEC”) announced the appointment of Deborah J. Jeffrey as Inspector General effective May 7, 2023. Prior to this...more
On May 3, 2023, the Securities and Exchange Commission (the “SEC”) adopted a new rule (the “Rule”) that amends Form PF, the confidential reporting form for certain SEC-registered investment advisers to privately-offered...more
The U.S. Securities and Exchange Commission (SEC) adopted final amendments to Form PF, the confidential reporting form required for certain SEC-registered investment advisers (RIAs) to private funds, on 3 May 2023. The...more
On May 3, 2023, the SEC adopted amendments to Form PF, the confidential reporting form filed by certain SEC-registered investment advisers. The amendments are an effort to improve the ability of the Financial Stability...more
The U.S. Securities and Exchange Commission (the SEC) adopted Amendments to Form PF (the Amendments) in a three-to-two vote on May 3, 2023, over a decade after Form PF’s initial adoption. SEC Chair Gary Gensler predicted that...more
On May 3, 2023, the Securities & Exchange Commission (“SEC”) adopted amendments to Form PF (the “Final Amendments”). Plan fiduciaries that utilize private equity funds, and regulated entities that serve these plan sponsors,...more
On May 3, 2023, the US Securities and Exchange Commission (SEC), in a 3-2 decision, adopted a final rule that modifies Form PF’s reporting requirements for certain registered investment advisers to private equity funds, hedge...more
On May 3, 2023, the Securities and Exchange Commission (SEC) voted to adopt certain amendments (Final Amendments) to Form PF reporting requirements. Form PF is a confidential, regulatory reporting form filed by SEC-registered...more
Introduction and Summary - On 3 May 2023, the Securities and Exchange Commission (SEC) approved amendments to Form PF (the Amendments), the confidential reporting form required to be filed by certain SEC-registered private...more
On May 3, 2023, the Securities and Exchange Commission (the SEC) adopted, on a 3-2 vote, amendments to Form PF requiring certain current event reporting for Large Hedge Fund Advisers (as defined below), certain quarterly...more
On May 3, 2023, the Securities and Exchange Commission (the SEC) adopted important amendments to Form PF, the systemic risk reporting form for private fund advisers registered with the SEC, that would require (i) new...more
Editor's Note: This post provides a brief overview of the SEC's final rule. A more detailed discussion of the amendments will be covered in an upcoming Katten publication. On May 3, the Securities and Exchange Commission...more