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Investment Adviser Disqualification

Dechert LLP

Not Quite QPAMDEMONIUM: DOL Issues Final Changes to the QPAM Exemption

Dechert LLP on

On April 3, 2024, the Department of Labor (the “DOL”) issued its final amendment (“Final Amendment”) to Prohibited Transaction Class Exemption 84-14, commonly referred to as the “QPAM Exemption”. Generally, the QPAM...more

Cadwalader, Wickersham & Taft LLP

SEC Proposes Significant Amendments to Investment Adviser Solicitation Rule

The Securities and Exchange Commission (the “Commission” or the ”SEC”), on November 4, approved the publication of a substantial release (the “Release”) proposing significant amendments to the rules under the Investment...more

Dorsey & Whitney LLP

The Disqualification Provisions and the SEC’s Use of Wavers

Dorsey & Whitney LLP on

One key debate regarding current SEC enforcement policy centers on the application of the so-called “bad actor” provisions. Previously the Commissioners split over the nature, use and application of those provisions. ...more

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