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SEC Marketing Rule FAQs Yield New Guidance

On 19 March 2025, the Securities and Exchange Commission staff issued updated frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the Marketing Rule) (available here)....more

The SEC Fines Stand-Alone Adviser for Off-Channel Communications

Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more

The SEC's New Private Fund Adviser Rules: A Guide to Compliance (Updated)

On 23 August, the US Securities and Exchange Commission adopted new rules and rule amendments that will impose substantial regulation on the management and operation of private funds by investment advisers. The Guide to...more

The SEC's New Private Fund Adviser Rules: A Guide to Compliance

On 23 August, the US Securities and Exchange Commission adopted new rules and rule amendments that will impose substantial regulation on the management and operation of private funds by investment advisers. The Guide to...more

SEC Proposes Custody Rule Overhaul With Broad Implications for Investment Advisers, Custodians, and Independent Public Accounting...

On 15 February 2023, the Securities and Exchange Commission (SEC) announced a proposed overhaul of the custody framework for SEC-registered investment advisers (investment advisers). The proposed reforms—which would amend and...more

SEC Increases the "Qualified Client" Net Worth and Assets Under Management Thresholds

INTRODUCTION - On 17 June 2021, the U.S. Securities and Exchange Commission (the SEC) issued an order to: (i) increase the net worth threshold for “qualified clients” under Rule 205-3 of the Investment Advisers Act of 1940,...more

The SEC's Modernized Marketing Rule for Investment Advisers

On 22 December 2020, the U.S. Securities and Exchange Commission (SEC) adopted amendments (the final rule) to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the Advisers Act) to modernize the regulation of...more

Now Effective: SEC Interpretations Relating to the Fiduciary Duty of Investment Advisers and the “Solely Incidental” Exclusion

At an Open Meeting on June 5, 2019, the Securities and Exchange Commission (“SEC”) formally adopted: (1) an interpretation of an investment adviser’s fiduciary duties; and (2) an interpretation of the “solely incidental”...more

SEC Outlines Parameters of Permissible Broker-Dealer Advice to Customers

On June 5, 2019, the Securities and Exchange Commission (“SEC” or “Commission”) issued a new interpretation (“Interpretation”) of the “solely incidental” prong of Section 202(a)(11)(C) of the Investment Advisers Act of 1940,...more

SEC Publishes a Roadmap to Navigating the Investment Adviser Fiduciary Duty

On June 5, 2019, the U.S. Securities and Exchange Commission (the “SEC”) adopted a final interpretation (the “Interpretation”) of the standard of conduct applicable to investment advisers (“IA”) under the Investment Advisers...more

Triggering Regulation Best Interest: What Are “Retail Customers” and “Recommendations”

On June 5, 2019 the Securities and Exchange Commission (“SEC” or the “Commission”) adopted Regulation Best Interest to require broker-dealers to observe a new standard of conduct when recommending securities or investment...more

SEC Adopts A New Best Interest Standard of Conduct

Securities firms should begin reviewing their business models and account types to determine if they will be subject to a sweeping investor-protection regulatory regime recently adopted by the Securities and Exchange...more

Be Careful What you Post - SEC Continues To Focus on the Use of Social Media by Investment Advisers

On July 10, 2018, the Securities and Exchange Commission (the “SEC”) reaffirmed the application of the securities laws to social media use. Specifically, the SEC published five settlement orders (the “Settlements”) arising...more

Calm Before the Storm: Investment Advisers Face Changes to the Advertising Rule, GIPS, and Performance Portability Standards

In recent months, a series of regulatory developments have clarified current guidance and signaled the potential for significant future changes to the rules that govern performance presentations by investment advisers. ...more

SEC Staff Identifies Several Paths to “Inadvertent Custody” Under the Advisers Act Custody Rule

Last week, the staff of the Securities and Exchange Commission (“SEC”) clarified its views on certain arrangements that can result in investment advisers having “custody” of client assets, as defined in rule 206(4)-2 (the...more

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