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Investment Company Status Considerations for Cash Positioning in Wake of Bank Failures

Given this week’s headlines, many emerging companies may be asking themselves: “Why am I holding so much cash?” The Investment Company Act of 1940 (the 1940 Act) may be to blame. “But I don’t have any intention of...more

SEC Overhauls Registered Investment Adviser Marketing Rules

The U.S. Securities and Exchange Commission (SEC or the Commission) on December 22, 2020, amended the main advertising rule under the Investment Advisers Act of 1940 (the Advisers Act) as part of a rulemaking package...more

Preparing for the SEC’s Increased Pursuit of Compliance Officers

The SEC’s recent aggressive enforcement posture against chief compliance officers has raised many concerns, including whether the SEC’s actions are actually chilling robust compliance efforts. To protect themselves against...more

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