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Investment Adviser

Morgan Lewis

Securities Enforcement Roundup – April 2026

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In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments from April 2026. In April 2026: On April 7, the SEC announced its enforcement results for the fiscal year that...more

Baker Donelson

Top 10 Mistakes Registered Investment Advisers Make When Selling Their Firms

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The decision to sell a registered investment adviser (RIA) is one of the most significant – and most complex – decisions an RIA owner will ever navigate, and avoiding the most common mistakes will help sellers achieve their...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update March – April 2026

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Section 205(a)(1) of the Advisers Act generally prohibits an investment adviser from entering into an investment advisory contract that charges a performance-based fee – i.e., compensation to the adviser based on a share of...more

Katten Muchin Rosenman LLP

SEC Adopts Inflation-Based Adjustment to 'Qualified Client' Thresholds for Performance Fees

On April 28, 2026, the Securities and Exchange Commission (SEC) issued a final order adjusting for inflation the dollar amount thresholds used to determine whether an investor qualifies as a “qualified client” in order to...more

BCLP

SEC and CFTC Propose Significant Rollback of Form PF Reporting Requirements

BCLP on

On April 20, 2026, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) jointly proposed amendments to Form PF, the confidential reporting form filed by certain SEC-registered...more

Polsinelli

SEC Increases Qualified Client Thresholds for Performance Fee Arrangements

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Key Takeaways: The SEC has increased the qualified client thresholds under Rule 205-3 effective June 29, 2026, raising the assets-under-management test to $1.4 million and the net worth test to $2.7 million. The changes...more

Holland & Knight LLP

Regulation S-P Amendments: Compliance Deadline Approaching for "Smaller Entities"

Holland & Knight LLP on

The June 3, 2026, deadline for "smaller entities" to comply with the 2024 amendments to U.S. Securities and Exchange Commission (SEC) Regulation S-P is fast approaching. This Holland & Knight alert provides a brief overview...more

Barnea Jaffa Lande & Co.

The ISA Publishes: Directive Regulating One-Off Advisory Services and Alternative Assets

The Israel Securities Authority (ISA) has published a new draft directive for public comments that will comprehensively regulate the activities of licensed investment advisors and marketers when providing one-off services and...more

Troutman Pepper Locke

Investment Management Update – Q1 2026

Troutman Pepper Locke on

In This Update - Covering legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended March 31. On January 22, the Securities and Exchange Commission’s (SEC) Small...more

Morgan Lewis

SEC and CFTC Propose Amendments to Form PF to Reduce Reporting Burdens

Morgan Lewis on

On April 20, 2026, the US Securities and Exchange Commission (SEC) and US Commodity Futures Trading Commission (CFTC and, together with the SEC, the Commissions) jointly proposed amendments to Form PF (Proposed Amendments)...more

Mayer Brown Free Writings + Perspectives

“FINRA Forward: A Year of Progress” Report Highlights Achievements and Foreshadows Upcoming Proposals

In April 2026, FINRA published its report titled “FINRA Forward: A Year of Progress,” which provides a recap of the regulatory changes implemented by FINRA as part of its rule modernization initiative.  The report also...more

Carlton Fields

FINRA Proposes to Permit Performance Projections and Targeted Returns: Proposal Would Help Level the BD/RIA Playing Field

Carlton Fields on

In February 2026, the Financial Industry Regulatory Authority (FINRA) proposed amendments to its Rule 2210(d)(1)(F) that would permit member firms to include performance projections and targeted returns in communications to...more

Mayer Brown Free Writings + Perspectives

Co-Investment Relief for Open-End Funds

The Staff of the SEC’s Division of Investment Management issued a no-action letter on April 27, 2026 to J.P. Morgan Investment Management, Inc. (“JPMIM”) addressing the application of an existing co-investment exemptive order...more

Alston & Bird

SEC/CFTC Propose Amendments to Reduce Form PF Reporting Burdens

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Our Investment Funds Team examines how a Proposed Rule from the Securities and Exchange Commission and Commodity Futures Trading Commission would narrow Form PF’s reach and reduce reporting burdens for many smaller private...more

Sullivan & Worcester

SEC Broadens Closed-End Fund/BDC Co-Investment Relief to Open-End Funds

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On April 27, 2026, the SEC Staff issued a no-action letter to J.P. Morgan Investment Management Inc. (“JPMIM”), an investment adviser to a large complex of registered and non-registered funds,...more

Vedder

SEC and CFTC Propose Significant Rollback of Form PF Reporting Requirements

Vedder on

On April 20, 2026, the Securities and Exchange Commission and the Commodity Futures Trading Commission jointly proposed amendments that would significantly narrow the scope of Form PF....more

Paul Hastings LLP

SEC and CFTC Propose Form PF Amendments to Eliminate and Streamline Filing Requirements for Smaller Investment Advisers

Paul Hastings LLP on

On April 20, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) jointly issued proposed amendments to Form PF (Proposed Amendments), the nonpublic filing required of certain...more

Ropes & Gray LLP

No-Action Letter Permits Open-End Fund Participation under Co-Investment Orders

Ropes & Gray LLP on

On April 27, 2026, the staff of the SEC’s Division of Investment Management (the “Staff”) issued a no-action letter (the “Letter”) to J.P. Morgan Investment Management Inc. (“JPMIM”) confirming that it would not recommend...more

McDermott Will & Schulte

SEC, CFTC propose streamlined Form PF

On April 20, 2026, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly proposed amendments to Form PF (the Proposing Release) that are intended to streamline reporting...more

Cooley LLP

AI Policy for Fund Managers

Cooley LLP on

Fund managers encounter AI tools everywhere, including in research workflows, communications, marketing, portfolio monitoring and compliance....more

Katten Muchin Rosenman LLP

Regulators Hit Reverse: SEC and CFTC Move to Scale Back Form PF

On April 20, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC, and together with the SEC, the “Agencies”) proposed a comprehensive overhaul of Form PF. Form PF is the...more

Seward & Kissel LLP

CFTC and SEC Propose Significant Amendments to Form PF

Seward & Kissel LLP on

On April 20, 2026, the Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”) jointly proposed substantial amendments to Form PF, which would meaningfully alter the scope and nature...more

Sullivan & Worcester

Rolling Back Private Fund Reporting: Proposed Amendments to Form PF

Sullivan & Worcester on

The U.S Securities and Exchange Commission (the “SEC”) and the U.S. Commodities Futures Trading Commission (the “CFTC”) have jointly proposed amendments (the “Proposed Amendments”) to Form PF....more

Bricker Graydon Wyatt LLP

Does the Vacatur of the 2024 Fiduciary Rule Change the Applicable Prohibited Transaction Exemption for Non‑Discretionary Fiduciary...

Recent federal court decisions vacating the Department of Labor’s (DOL) 2024 fiduciary rule have prompted a common and practical question from retirement plan service providers: Does this change affect whether we still need...more

Mitchell, Williams, Selig, Gates & Woodyard,...

When Selling Annuities Becomes Investment Advice: A Guide for Insurance Providers

For insurance companies and agents, the distinction between selling annuities and providing investment advice can blur unexpectedly. When annuity sales involve discussions about a client's securities portfolio or...more

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