On July 31, the Securities and Exchange Commission (SEC) Chairman Paul Atkins (Chair Atkins) presented “Project Crypto,” an initiative aimed at positioning the U.S. as the global leader in the digital finance world. In his...more
8/6/2025
/ Blockchain ,
Capital Markets ,
Crypto Exchanges ,
Cryptoassets ,
Decentralized Finance (DeFi) ,
Digital Assets ,
FinTech ,
Investment ,
Regulatory Agenda ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
Since the House passed the CLARITY Act on July 17, the U.S. Senate Banking Committee, which has oversight of the Securities and Exchange Commission (SEC), has been busy working on its own version of the U.S. crypto regulatory...more
8/5/2025
/ Ancillary Agreements ,
Anti-Money Laundering ,
Blockchain ,
BSA/AML ,
CFTC ,
Cryptoassets ,
Digital Assets ,
Investment ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Senate Banking Committee
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
7/23/2025
/ Anti-Money Laundering ,
BSA/AML ,
Effective Date ,
Exemptions ,
Final Rules ,
Financial Crimes ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment ,
Investment Adviser ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process
On June 24, Senate Banking Chairman Tim Scott (R-SC), Subcommittee on Digital Assets Chair Cynthia Lummis (R-WY), Senator Thom Tillis (R-NC), and Senator Bill Hagerty (R-TN) released a set of guiding principles for the...more
6/27/2025
/ Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Markets ,
Financial Regulatory Reform ,
Investment ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Securities Regulation ,
Senate Banking Committee ,
Stablecoins
On June 17, the U.S. Senate voted 68-30 to pass S.1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the Act). This represents a landmark effort by the U.S. Congress to...more
6/25/2025
/ Anti-Money Laundering ,
Bankruptcy Code ,
BSA/AML ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
FinTech ,
Investment ,
National Security ,
Popular ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Requirements ,
Stablecoins ,
Virtual Currency
In this episode of the Crypto Exchange, Genna Garver is joined by John D'Agostino, head of strategy for Coinbase Institutional, to discuss the significant developments in the crypto industry following the Senate's approval of...more
FUNDamentals is a periodic digest of news and information specifically for private funds and their managers. In this issue, we highlight some fundraising trends, new marketing rule FAQs, fund liquidity trends (limited...more
6/17/2025
/ Federal Budget ,
Financial Markets ,
Financial Services Industry ,
Fund Managers ,
Investment ,
Investment Funds ,
Investment Management ,
Limited Partnerships ,
Liquidity ,
Private Equity ,
Private Equity Funds ,
Proposed Legislation ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration
On Tuesday, June 10, the House Committees on Agriculture and Financial Services both favorably reported to the House H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act (as amended). Both committees gave overwhelmingly...more
6/12/2025
/ CFTC ,
Consumer Financial Products ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
Government Agencies ,
Investment ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
After years of uncertainty and regulation by enforcement, the U.S. may finally be moving toward a more comprehensive framework for the regulation of digital assets. On June 4, 2025, the House Committee on Financial Services...more
6/10/2025
/ Blockchain ,
CFTC ,
Commodities ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
Investment ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Securities Regulation ,
Stablecoins
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
On April 10, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance (the Division) issued a statement aimed at providing greater clarity on the application of federal securities laws to crypto assets....more
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
On August 28, the U.S. Securities and Exchange Commission (SEC) adopted amendments to certain registered investment companies (funds) reporting requirements. The SEC originally proposed the amendments on November 2, 2022....more
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
The National Association of Insurance Commissioners (NAIC) held its Summer National Meeting, at which it adopted new guidelines allowing state regulators or NAIC staff to override formerly automatic ratings on investments....more
Insurance Companies investing in private credit funds should be prepared for...more
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
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
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
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
5/10/2024
/ AML/CFT ,
Anti-Money Laundering ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Investment Management ,
New Guidance ,
New Rules ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
SRO ,
Suspicious Activity Reports (SARs)
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
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
On August 23, the Securities and Exchange Commission finalized the Private Funds Rules. Listen to Troutman Pepper Partner Genna Garver and Fairview General Counsel and Executive Vice President Amber Allen as they discuss the...more
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
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