On August 15, 2025, the Division of Investment Management (the “Division”) of the U.S. Securities and Exchange Commission (SEC) published Accounting and Disclosure Information 2025-16 (ADI), providing updated guidance for...more
8/19/2025
/ Closed-End Funds ,
Disclosure Requirements ,
Division of Investment Management ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
Investment Company Act of 1940 ,
Investment Funds ,
Investment Management ,
New Guidance ,
Private Funds ,
Registered Investment Advisors ,
Registration Requirement ,
Regulatory Requirements ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC)
On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more
7/23/2025
/ AML/CFT ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Effective Date ,
Final Rules ,
FinCEN ,
Investment Management ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
SAR ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
On March 19, 2025, the staff of the SEC’s Division of Investment Management issued two new FAQs related to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Rule”). The new guidance reduces the complexity of the...more
3/28/2025
/ Asset Management ,
Disclosure Requirements ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Marketing ,
New Guidance ,
Private Funds ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
The Department of Labor (DOL) recently issued a final amendment (“Final Amendment”) to Prohibited Transaction Exemption (PTE) 84-14, which is otherwise known as the “QPAM Exemption.” The QPAM Exemption is a prohibited...more
6/21/2024
/ Compliance ,
Criminal Convictions ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Exemptions ,
Individual Retirement Account (IRA) ,
Investment Management ,
Prohibited Transactions ,
QPAM ,
Recordkeeping Requirements ,
Reporting Requirements ,
Retirement Plan
The Investment Advisers Act of 1940 (the “Advisers Act”) is a relatively compact statute, and for many years the Securities and Exchange Commission (SEC) adopted relatively few regulations specifically targeting Advisers Act...more
3/19/2024
/ Anti-Money Laundering ,
Asset Management ,
Compliance ,
Fiduciary Duty ,
Investment Adviser ,
Investment Management ,
Pay-To-Play ,
Proxy Voting ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC)
The compliance date for the SEC’s new investment adviser Marketing Rule is November 4, 2022, allowing just over a month for an investment adviser to finalize its implementation process to comply with the Rule, which applies...more