With less than a day to go before the 12 June 2025 compliance date for the SEC and CFTC’s jointly adopted amendments to Form PF, the SEC, together with the CFTC, voted today to further extend the compliance date for the...more
On 12 March 2025, the US Securities and Exchange Commission (SEC) staff issued a no-action letter that provides private fund sponsors with a concrete, streamlined approach to relying on Rule 506(c), based on minimum...more
On 12 March 2025, the SEC staff issued a no-action letter for offerings under Rule 506(c) of Regulation D. In the letter, the Staff concurs that an issuer will have taken “reasonable steps to verify” a purchaser’s accredited...more
2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more
2/12/2025
/ Asset Management ,
Australia ,
Capital Markets ,
Cryptoassets ,
Cryptocurrency ,
Disclosure Requirements ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Fiduciary Duty ,
Financial Services Industry ,
Foreign Investment ,
Hong Kong ,
Investment Firms ,
Investment Funds ,
Investment Management ,
Investors ,
Japan ,
Regulatory Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Singapore ,
Sustainability ,
Sustainable Finance
Kamala Harris’ selection of Tim Walz as running mate for her presidential campaign has implications under the Securities and Exchange Commission’s (SEC) Rule 206(4)-5 under the Investment Advisers Act (SEC Pay-to-Play Rule)....more
Brief Overview - On 8 February 2024, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF (the Amendments), the confidential reporting form...more
3/6/2024
/ Asset Management ,
CFTC ,
Compliance ,
Digital Assets ,
Disclosure Requirements ,
Hedge Funds ,
Investment Adviser ,
Investment Funds ,
Investors ,
Private Funds ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
It is a dramatic understatement to describe 2023 as a busy year in the United States for asset management regulation. With 24 rules adopted and 18 new rules or rule amendments proposed, the US Securities and Exchange...more
1/22/2024
/ Asset Management ,
Beneficial Owner ,
Capital Markets ,
Compliance ,
Digital Assets ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Corrupt Practices Act (FCPA) ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Management ,
Liquidity ,
Money Market Funds ,
Private Funds ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Standards ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Swing Pricing ,
Whistleblowers
Introduction and Summary - On 3 May 2023, the Securities and Exchange Commission (SEC) approved amendments to Form PF (the Amendments), the confidential reporting form required to be filed by certain SEC-registered private...more
The Securities and Exchange Commission (the SEC) on 9 February 2022 proposed new rules and amendments (collectively, the Proposed Rules) under the Investment Advisers Act of 1940, as amended (the Advisers Act)....more
On 26 January 2022, the U.S. Securities and Exchange Commission (SEC) proposed amendments to Form PF, the confidential reporting form required to be filed by certain advisers to private funds. If adopted, the proposed...more
INTRODUCTION - On 26 August 2020, the U.S. Securities and Exchange Commission (the SEC) adopted amendments to Rule 501(a) of Regulation D promulgated under the Securities Act of 1933, as amended (the Securities Act), which...more
On 10 July 2020, the Securities and Exchange Commission (SEC) proposed amending Form 13F and Rule 13f-1 to raise the reporting threshold at which institutional investment managers are required to complete and file Form 13F...more
I. INTRODUCTION -
On December 18, 2019, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to Rule 501(a) of Regulation D promulgated under the Securities Act of 1933, as amended (“Securities Act”),...more
AGENDA -
- Background
- Regulation Best Interest
- Judicial Challenges to Regulation Best Interest
- Form CRS
- Interpretation of Investment Adviser’s Fiduciary Duty
- Interpretation of the “Solely Incidental” Prong...more
Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more
The Treasurer of the Commonwealth of Pennsylvania has prohibited investment managers from using third-party placement agents for funds managed on behalf of the Commonwealth of Pennsylvania Treasury Department. The Treasury...more
The federal Pay-to-Play Rules may impact campaign contributions in the 2016 election and, in particular, campaign contributions to a major party’s presidential campaign. Financial institutions that do business with, or seek...more
Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more