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SEC Examination Priorities Signal Capital Markets Enforcement

The Securities and Exchange Commission’s Division of Examinations recently released its 2025 priorities. These identify several new or emerging areas of focus that could be precursors to enforcement actions, such as the use...more

SEC Division of Examinations: 2025 Examination Priorities

Last week, the Securities and Exchange Commission’s Division of Examinations (the “Division”) released its 2025 examination priorities, an annual publication by the Division designed to make the public aware of issues, areas,...more

SEC Decides Not To Seek Supreme Court Review of Decision Vacating Private Fund Rules

The Securities and Exchange Commission (“SEC”) has decided not to petition the U.S. Supreme Court for a writ of certiorari to review the U.S. Court of Appeals for the Fifth Circuit’s decision to vacate a controversial package...more

SEC Department of Examinations Issues Risk Alert on Marketing Rule Deficiencies

Last week, the Securities and Exchange Commission’s Division of Examinations (“DOE”) issued a Risk Alert (the “Alert”) entitled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” The Alert describes...more

Investment Funds & Private Capital Market Insights: SEC Announces 2024 Examination Priorities

The SEC’s Division of Examinations (“DOE”) recently released its 2024 examination priorities (available here). The SEC provides examination priorities on an annual basis to convey to registrants specific areas that DOE will...more

Investment Funds & Private Capital Market Insights: SEC Charges Nine Investment Advisers for Advertising Hypothetical Performance...

On September 11, 2023 the SEC announced settlements with nine registered investment advisers (the “Advisers”) for alleged violations of the Investment Advisers Act’s new marketing rule (Rule 206(4)-1, available here, the...more

Investment Funds & Private Capital Market Insights: Industry Groups Challenge Over Private Funds Rule - Stay Current September...

On September 1, 2023, a group of private fund industry groups filed a petition in the United States Court of Appeals for the Fifth Circuit, challenging the SEC’s recently adopted Private Funds Rule (defined below). Our...more

Investment Funds & Private Capital Market Insights: SEC Adopts Scaled-Back Version of Private Fund Rules (Part 1 of 2)

On August 23, 2023, the SEC voted (3-2) to adopt new rules and amendments under the Investment Advisers Act of 1940 applicable to private fund advisers (available here), which were initially proposed in February 2022. The...more

SEC Charges FinTech Adviser for Misrepresenting Hypothetical Crypto Performance Resulting in Million Dollar “Marketing Rule”...

On August 21, 2023 the SEC announced charges (available here) against a FinTech-focused registered investment adviser (the “Adviser”) alleging the use of misleading hypothetical performance metrics in advertisements....more

SEC Adopts Updates to Private Fund Reporting on Form PF

On May 3, 2023, the SEC approved amendments to Form PF reporting requirements for private fund managers. Most significantly, the updates introduce new event reporting obligations for SEC-registered private fund advisers,...more

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