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SEC Clarifies When Gross-Only Performance May Be Permissible

The US Securities and Exchange Commission staff (Staff) has issued revised guidance regarding the application of Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (Marketing Rule), providing flexibility for...more

SEC Permits Rule 506(c) Accredited Investor Verification with Self-Certification

The US Securities and Exchange Commission (SEC) has published no-action guidance providing clarity to issuers relying on Rule 506(c) of Regulation D – an exempt offering pathway that permits issuers to publicly advertise an...more

Fifth Circuit Vacates Stay of Corporate Transparency Act Injunction, Again Putting Deadlines on Hold

On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more

Fifth Circuit Stays Injunction Halting Corporate Transparency Act’s Enforcement; Treasury Updates Deadline to January 13, 2025 for...

On December 23, 2024, the US Court of Appeals for the Fifth Circuit issued an order granting the government's emergency motion for a stay pending appeal of the preliminary injunction against the Corporate Transparency Act...more

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