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New EXAMS Guidance – Next Steps for Private Fund Managers

On June 8, 2023, the SEC Division of Examinations staff (EXAMS) published a risk alert focused on the new Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940). While this new risk alert largely mirrors...more

2023 Compliance Developments and Calendar for Private Fund Advisers

INTRODUCTION - Registered investment advisers to private funds clients are required to make filings with the Securities and Exchange Commission (SEC) each year and deliver certain information to their clients. In...more

SEC Staff Extends ‘Net’ Performance Presentation Requirement to Case Studies

As a general principle, the Marketing Rule requires registered investment advisers to include net performance alongside any presentation of gross performance. Market practice on whether or how this principle applies to case...more

2022 Compliance Developments and Calendar for Private Fund Advisers

Compliance Reminders for 2022 - Registered investment advisers to private funds clients are required to make filings with the Securities and Exchange Commission (SEC) each year and deliver certain information to their...more

Compliance Reminder: BE-180 Survey of Cross-Border Financial Services Transactions

U.S. persons who provided or received any financial services, such as investment advisory services, fund management or brokerage services, to or from non-U.S. persons during 2019 (“Reporters”) must file a Form BE-180 report...more

SEC Issues New Cybersecurity Guidance for Investment Funds

On April 28, the Securities and Exchange Commission (SEC) Division of Investment Management (the “Division”) published a Guidance Update setting forth cybersecurity concerns and advice for the registered investment ...more

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