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Fund Managers Reporting Requirements

Foley Hoag LLP

The Corporate Transparency Act: Impact on Private Fund Managers

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Private fund managers are reminded that the Corporate Transparency Act (CTA) may trigger reporting obligations to the Department of the Treasury’s Financial Crimes Enforcement Network for private fund managers and the private...more

Seward & Kissel LLP

SEC Drops Swing Pricing, Adopts Amendments to Form N-PORT and N-CEN and Issues Guidance on Open-End Fund Liquidity Risk Management...

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Who may be interested: Registered Investment Companies; Boards of Directors; Investment Advisers; Compliance Officers; Fund Administrators- Quick Take: In its August 28, 2024, open meeting, the SEC amended fund reporting...more

Foley Hoag LLP

TIC Form SHL-Reporting of Foreign Holdings of U.S. Securities Due August 30, 2024

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Form SHL is a five-year mandatory benchmark survey filing commissioned by the Department of the Treasury and administered by the Federal Reserve Bank of New York (“FRBNY”) applicable to all U.S.-resident issuers with foreign...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

Sullivan & Worcester

Deadline for Form 13F Filers for New Reporting Requirements on Executive Compensation Votes Rapidly Approaching

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The Securities and Exchange Commission adopted rule and form amendments that will require institutional investment managers who file Form 13F to use Form N-PX to report how they voted proxies on executive compensation (or...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

Seyfarth Shaw LLP

SEC's Private Fund Advisers Rule Struck Down by Fifth Circuit

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The Fifth Circuit Court of Appeals (Fifth Circuit) today issued its ruling striking down the “Private Fund Advisers Rule” (the “PFA”). The proposed PFA was introduced on February 9, 2022 (“Proposed Rule”). The Securities and...more

Goodwin

Horizon Scan for Private Investment Funds - May 2024

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Welcome to the second edition of our Horizon Scan for 2024: key recent and expected funds, regulatory, and tax developments to look out for. As before, we focus on the most important developments and changes that we expect to...more

SEC Compliance Consultants, Inc. (SEC³)

Top Tips for Updating Your 2024 Compliance Program

Every year compliance officers face the unenviable job of performing their compliance program's annual review under Advisers Act Rule 206(4)-7). An essential element of that review is updating the firm's compliance policies...more

Akin Gump Strauss Hauer & Feld LLP

Reminder to Managers re Upcoming Changes to EMIR Reporting

The European Market Infrastructure Regulation (EMIR) data reporting requirements apply to European Union (EU) funds and EU fund managers. UK EMIR imposes reporting requirements on UK funds and UK managers. The reporting...more

Mayer Brown

TCFD Reporting Pensions Regulator Review of 2023 Reports

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The Pensions Regulator (TPR) has published its latest review of pension scheme TCFD reports. This sets out TPR’s observations, feedback and suggested improvements for a selection of 30 reports published in 2023 (10% of the...more

Akin Gump Strauss Hauer & Feld LLP

Update (2): The NY LLC Transparency Act and Corporate Transparency Act’s Impact on Private Fund Managers

In the weeks since publishing our original alert, FinCEN released several frequently asked questions (FAQs) on the application of the Corporate Transparency Act (CTA). Private fund managers are likely to find two of these...more

Foley Hoag LLP

The Corporate Transparency Act: An Overview of the Impact on Private Funds

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What is the purpose of the Corporate Transparency Act (“CTA”)? Effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) imposed new federal reporting obligations on certain companies, including potentially...more

Lowenstein Sandler LLP

The SEC’s Private Fund Adviser Rules Explained — Part 4: The Quarterly Statement Rule

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As we have discussed in earlier Client Alerts, on August 23, 2023, the U.S. Securities and Exchange Commission (SEC) adopted new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act), to...more

Paul Hastings LLP

New AIFMD Reporting System in Finland

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Non-European fund managers which have registered funds for marketing in Finland under the Finnish national private placement regime (implementing A.42 of the AIFMD), will be required to complete periodic reporting to the...more

K&L Gates LLP

The SEC's New Private Fund Adviser Rules: A Guide to Compliance

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On 23 August, the US Securities and Exchange Commission adopted new rules and rule amendments that will impose substantial regulation on the management and operation of private funds by investment advisers. The Guide to...more

K&L Gates LLP

What's in a Fund Name? SEC Approves Changes to the Fund Names Rule

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On 20 September 2023, the US Securities and Exchange Commission (the SEC) adopted amendments to Rule 35d-1 (the Names Rule or Rule) under the Investment Company Act of 1940, as amended (the 1940 Act), and made related form...more

Proskauer Rose LLP

Taskforce on Nature-Related Financial Disclosures – New and Updated Nature Reporting Recommendations Published

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The NY Climate Week conference took place during the week of 18 September 2023, bringing together international leaders from business and governments. During the conference the Taskforce on Nature-related Financial...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

Lowenstein Sandler LLP

SEC Enacts Wide-Sweeping Private Funds Rules

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On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) announced the enactment of a series of new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act). We refer to these...more

Sullivan & Worcester

SEC Adopts Highly Anticipated Private Funds Rules

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The U.S. Securities and Exchange Commission (the “SEC”) last week adopted highly anticipated new rules and amendments (the “Adopted Rules”) to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), that will...more

WilmerHale

SEC Makes Sweeping Changes to Private Fund Adviser Regulatory Regime: Mandates Quarterly Reporting, Restricts Preferential...

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In a 3-2 vote on August 23, 2023, the Securities and Exchange Commission (“SEC” or “Commission”) adopted five new rules under the Investment Advisers Act of 1940 (the “Advisers Act”), collectively called the “Private Fund...more

Foley Hoag LLP

Final Private Fund Adviser Rules

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On August 23, 2023, the Securities and Exchange Commission (the “SEC”) approved by a 3-2 vote a final rule enacting a series of wide-sweeping changes to the regulation of the private funds industry (the “Final Rule”). While...more

DarrowEverett LLP

What SEC’s Transparency Rule Means for Investors, Advisers and Funds

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Earlier this summer, we wrote about both new and amended rules proposed by the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”) regarding private funds, their advisers,...more

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