On March 12, 2025, the staff of the Securities and Exchange Commission (“SEC”) issued no-action guidance providing that certain minimum investment amounts, along with certain written representations from the purchaser, could...more
On March 19, 2025, the Securities and Exchange Commission (“SEC”) updated its frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). The new FAQs permit...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
In a 3-0 decision, the Fifth Circuit Court of Appeals vacated the SEC’s private fund adviser rules (“Final Rule”). Each component of the Final Rule was vacated, including the Private Fund Audit Rule, Private Fund Quarterly...more
On March 27, 2024, the staff of the SEC’s Division of Examinations issued a risk alert highlighting its intent to focus, during examinations and outreach on market participants’ preparations for the shortening of the standard...more
Background of Proxy Voting Requirements -
On December 1, 2022, the U.S. Department of Labor (“DOL”) released its final rule regarding investment duties of fiduciaries under ERISA (referred to as the “ESG Rule”). The ESG...more
On June 15, 2020, SEC Chairman Jay Clayton released a public statement confirming the June 30, 2020 compliance date for Regulation Best Interest (Reg BI) and Form CRS. Reg BI establishes a new standard of conduct for...more
On April 7, 2020, the Securities and Exchange Commission’s (the “SEC” or the “Staff”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert1 to provide broker-dealers and their associated persons...more
5/8/2020
/ Broker-Dealer ,
Compliance ,
Conflicts of Interest ,
Coronavirus/COVID-19 ,
Disclosure ,
Document Requests ,
Financial Industry Regulatory Authority (FINRA) ,
OCIE ,
Regulation Best Interest ,
Risk Alert ,
Securities and Exchange Commission (SEC)
On April 7, 2020, the Securities and Exchange Commission’s (the “SEC” or the “Staff”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide SEC-registered broker-dealers and investment...more
On April 27, 2020, the staff of the Securities and Exchange Commission (the “SEC”) updated its Division of Investment Management Coronavirus (COVID-19) Response FAQs and Staff Responses to Questions About the Custody Rule...more
The Financial Industry Regulatory Authority (“FINRA”) has published multiple Regulatory and Information Notices and created a webpage within FINRA.org to address the COVID-19 outbreak. Key highlights concerning FINRA guidance...more
New Rules, Proposed Rules, Guidance and Alerts –
PROPOSED RULES –
Agencies Propose Volcker Rule Amendments Relating to Covered Funds –
On January 30, 2020, the Federal Reserve Board, FDIC, OCC, SEC and CFTC proposed...more
3/3/2020
/ Cybersecurity ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Investment Fund ,
Investment Funds ,
New Guidance ,
OCIE ,
Proposed Rules ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Sub-advisers ,
Volcker Rule
On January 9, 2020, FINRA released its 2020 Risk Monitoring and Examination Priorities Letter for its member firms. The exam priorities are organized into four categories: (1) sales practice and supervision; (2) market...more
2/27/2020
/ Best Execution ,
Compliance ,
Consolidated Audit Trail ,
Digital Assets ,
Financial Industry Regulatory Authority (FINRA) ,
Form CRS ,
Initial Public Offering (IPO) ,
Investment Adviser ,
Liquidity ,
Regulation Best Interest ,
Regulation BI ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC)
On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted three to one to approve a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with...more
9/13/2019
/ Best Interest Standard ,
Books & Records ,
Broker-Dealer ,
Conflicts of Interest ,
Disclosure Requirements ,
Duty of Care ,
Duty of Loyalty ,
Fiduciary Duty ,
Filing Requirements ,
Form CRS ,
Investment Advisers Act of 1940 ,
Investment Management ,
Investors ,
Recordkeeping Requirements ,
Regulation BI ,
Securities Transactions
The U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) held its annual SEC Speaks conference in Washington, DC on April 8 and 9, 2019. The conference featured remarks from the Chairman and commissioners,...more
4/12/2019
/ Administrative Law Judge (ALJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Investment Banks ,
Investors ,
Kokesh v SEC ,
Lorenzo v SEC ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations