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FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

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

Investment Management Update - Q2 2024

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

The SEC's New Marketing Rule - Practically Speaking: General Prohibitions

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC's New Marketing Rule - Practically Speaking: Hypothetical Performance

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC's New Marketing Rule - Practically Speaking: Performance Advertising/Track Records

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC’s New Marketing Rule - Practically Speaking: What Is an Advertisement?

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

The SEC's New Marketing Rule - Practically Speaking: Testimonials and Endorsements

In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

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