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FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Investment Management Update - Q1 2025

Explore the latest legal developments and regulatory updates impacting funds, advisers, and industry participants, including SEC rule amendments, compliance extensions, and guidance on accredited investor verification....more

FUNDamentals: Form N-PX — Institutional Investment Managers Must File, Even if No ‎Proxies Were Voted

With Form ADV annual updating amendments due for many investment advisers by the end of next month, advisers should consider whether to update their proxy voting policies and related disclosure in Part 2A, Item 17 in light of...more

The SEC’s Division of Examinations Announces 2025 Priorities

On October 21, the Securities and Exchange Commission’s (SEC) Division of Examinations announced its 2025 examination priorities (2025 guidance) for registered investment advisers and investment companies, broker-dealers,...more

Investment Management Update - Q2 2024

This update covers legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended June 30. Rulemaking and Guidance: • SEC Issues Third Marketing Rule Risk Alert for...more

SEC Charges Broker-Dealer and Two Affiliated Investment Advisers With Violating Whistleblower Protection Rule

On September 4, the Securities and Exchange Commission (SEC) issued an order against three investment adviser firms for violating the whistleblower protections of Rule 21F-17(a) under the Securities Exchange Act of 1934. This...more

SEC Issues Third Marketing Rule Risk Alert for Investment Advisers

On April 17, the U.S. Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMS) issued its third risk alert on the amended Rule 206(4)-1 (the Marketing Rule) under the Investment Advisers Act of 1940...more

Investment Management Update - Q1 2024

This update covers legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended March 31. Rulemaking and Guidance: • SEC Adopts Reforms Relating to Investment Advisers...more

FinCEN Proposes New Investment Adviser AML Rule

On February 1/3, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule (the Proposed Rule), that, if adopted, would add certain investment advisers to the definition of “financial institution” under the Bank...more

A 2024 Economic Outlook - Troutman Pepper Podcast [Audio]

In this podcast episode, Genna Garver, a partner in the firm's Investment Funds + Investment Management Services practice, interviews Constance Hunter, a renowned economist known for her accurate predictions of important...more

SEC Adopts New Advisers Act Rules for Private Fund Advisers

On August 23, the Securities and Exchange Commission (SEC) adopted new rules (Adopting Release) for private fund advisers under the Investment Advisers Act of 1940, as amended (Advisers Act). The new rules require private...more

SEC Adopts Significant Amendments to Form PF

On May 3, the U.S. Securities and Exchange Commission (SEC) adopted significant amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. The final amendments will...more

SEC Issues Risk Alert on Safeguarding Customer Records and Information at Branch Offices

On April 26, the SEC’s Division of Examinations (EXAMS) issued a risk alert on the importance of broker-dealers and investment advisers (collectively, “firms”) establishing and following written policies and procedures aimed...more

Troutman Pepper's "Practically Speaking" Series Regarding the SEC's New Marketing Rule

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended....more

The SEC's New Marketing Rule - Practically Speaking: General Prohibitions

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC's New Marketing Rule - Practically Speaking: Hypothetical Performance

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC's New Marketing Rule - Practically Speaking: Performance Advertising/Track Records

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC’s New Marketing Rule - Practically Speaking: What Is an Advertisement?

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC's New Marketing Rule - Practically Speaking: Testimonials and Endorsements

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

SEC Proposes New Investment Adviser Outsourcing Oversight Requirements

On October 26, the Securities Exchange Commission (SEC) kicked off what’s expected to be an active season of fall rulemaking by proposing new Rule 206(4)-11 under the Investment Advisers Act of 1940, as amended (Advisers...more

Investment Management Update - June 2022

Covering legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended March 31, 2022. ...more

Investment Management Update - February 2022

Covering legal developments and regulatory news for funds, their advisers, and industry participants for the period July 2021 through December 2021. ...more

SEC Throws Down the Gauntlet and Proposes Significant New Private Fund Adviser Rules/Amendments to Existing Investment Advisers...

On February 9, the Securities and Exchange Commission (SEC) proposed numerous new rules and amendments to existing rules and Form ADV under the Investment Advisers Act of 1940, as amended (Advisers Act). The proposed changes...more

Investment Management Update - August 2021

Covering legal developments and regulatory news for funds, their advisers, and industry participants through June 2021. ...more

SEC Division of Examinations Issues Risk Alerts on Cross Trades and Wrap Fee Programs

On July 21, the Securities and Exchange Commission’s Division of Examinations (Division) released two separate “risk alerts,” encouraging investment advisers to implement written policies and procedures or review existing...more

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