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FINRA Proposes to Modify its Communications with the Public Rule to Allow More Parties to Receive Projections and Targeted Returns

In November of 2023, FINRA made an initial rule filing with the Securities and Exchange Commission (SEC) pursuant to Exchange Act Rule 19b-4, seeking to amend FINRA Rule 2210 – Communications with the Public (the...more

Private Fund Advisers: Presenting Track Record and Other Performance Information Under the Marketing Rule

Private fund advisers that are registered with the Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940 (the “Advisers Act”) are subject to certain rules governing their use of investment track...more

Key Highlights from California’s New Diversity Reporting Law

On October 8, 2023, California Governor Gavin Newsom signed into law Senate Bill 54[1] (the “Diversity Reporting Law”). The Diversity Reporting Law is intentionally broad in its scope and is intended to help highlight and...more

SEC Adopts Expansive Private Fund Adviser Rules

On August 23, 2023, the SEC adopted new rules and amendments to existing rules (collectively, the “New Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”). The New Rules are designed to increase...more

OCIE Publishes Observations From Examinations Of Private Fund Managers

On June 23, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert identifying common deficiencies and compliance issues it has observed in examinations of registered investment...more

COVID-19 FAQs For Private Fund Managers And Investors

During these unprecedented times, we are addressing a variety of questions and issues from fund managers relating to their investment vehicles. In this FAQ, we have focused on questions from investment advisers with respect...more

California Law Requires Enhanced Fee Disclosure for Public Pension and Retirement Systems Investing in Private Funds

Assembly Bill 2833 passed by the California legislature and signed into law by Governor Jerry Brown went into effect January 1, 2017, as California Government Code Section 7514.7 (“Section 7514.7”). It received wide support...more

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