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Are Secondaries and Fund of Funds Investments on the Horizon for Venture Capital Fund Managers?

On July 22, 2025, two new bills – the Developing and Empowering Our Aspiring Leaders Act of 2025 (DEAL Act) and the Improving Capital Allocation for Newcomers Act of 2025 (ICAN Act)1 – advanced out of the US House Financial...more

SEC Abandons Numerous Gensler-Era Proposed Rules

In just eight pages, the Securities and Exchange Commission (SEC) scrapped 14 proposed rules introduced between October 2020 and November 2023.1 Since taking office in April 2025, Chair Paul Atkins has struck a tone...more

Updated Marketing Rule FAQ Relieves Fund Managers From Calculating Investment-Level Net Returns

On March 19, 2025, staff from the Securities and Exchange Commission (SEC staff) updated its prior guidance regarding the requirement to show net returns of an individual investment, or subset of investments, in compliance...more

Are You a Fund Manager Looking to Set Up a Separate Entity and Avoid Registration? Recent SEC Enforcement Action Highlights Risks...

In a recent enforcement action announced by the Securities and Exchange Commission (SEC), the issue of how one investment adviser can affect the exemption status of related advisers under the Investment Advisers Act of 1940...more

FAQs on SEC’s Private Fund Adviser Rules After Fifth Circuit Decision

As most fund managers have likely heard by now, on June 5, 2024, the US Court of Appeals for the Fifth Circuit vacated the private fund adviser rules that the Securities and Exchange Commission (SEC) adopted in summer 2023,...more

Securities Laws Fundamentals for Venture Capital Fund Managers

If you’re starting out as a new firm and raising your first fund (or special purpose vehicle), there are a few securities laws principles that you’ll need to become familiar with. This post is intended to provide a quick...more

Facing the SEC’s New Rules for Venture Capital and Other Private Fund Advisers

Just over a month ago, the Securities and Exchange Commission (SEC) adopted new rules for venture capital (VC) and other private fund advisers under the Investment Advisers Act of 1940 (Advisers Act). These new rules, which...more

Becoming a Registered Investment Adviser: Worth the Costs?

There is one question that often confronts venture capital firms as they grow more successful and encounter new opportunities: Should we register with the Securities and Exchange Commission (SEC)? While there is no...more

Why Crypto Fund Managers Are Distressed Over the SEC’s Newly Proposed Safeguarding Rule

Note: This post is not intended to be a comprehensive summary of the Safeguarding Rule. Rather, it is intended to highlight some of the key requirements for fund managers should the SEC adopt the rule, as well as immediate...more

SEC Proposes New Rule and Record-Keeping Requirements for Outsourcing by Registered Investment Advisers

Engaging service providers and outsourcing various functions is a normal part of running an effective business. From the newest emerging managers to the most established ones, venture capital firms and private fund shops...more

Last-Minute Checklist for Private Fund Managers Complying With Marketing Rule

By now, registered investment advisers (RIAs) know that this is their last week to ensure they come into compliance with the “new” marketing rule under the Investment Advisers Act of 1940. While the Securities and Exchange...more

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