On March 19, 2025, the Securities and Exchange Commission (SEC) staff issued an update to its frequently asked questions (FAQ) guidance with respect to registered investment advisers’ compliance with Rule 206(4)-1 (Marketing...more
During an open meeting on Wednesday, August 23, 2023, the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) voted 3-2 along party lines to adopt new rules (collectively referred to as the “Private Funds...more
8/29/2023
/ Audits ,
Borrowing Statutes ,
Capital Markets ,
Clawbacks ,
Compliance ,
Dodd-Frank ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
Private Funds ,
Proposed Amendments ,
Proposed Rules ,
Securities and Exchange Commission (SEC)
On December 22, 2020, the Securities and Exchange Commission announced it had finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors....more
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) highlighted alternative data, or “alt data,” as a top examination priority. AIMA held a webinar on November 17, 2020, for...more
12/16/2020
/ AIMA ,
Breach of Contract ,
Compliance ,
Data Mining ,
Due Diligence ,
Employee Training ,
Infringement ,
Investment Advisers Act of 1940 ,
MNPI ,
OCIE ,
Securities and Exchange Commission (SEC) ,
Web Scraping
The Office of Compliance Inspections and Examinations (OCIE) issued a risk alert on November 19, 2020 related to the Advisers Act compliance rule, Rule 206(4)-7. Some key takeaways for Chief Compliance Officers (CCOs) are as...more
On November 2, 2020, the SEC’s Division of Enforcement issued its 2020 Annual Report for the fiscal year ending September 30, 2020. While the Enforcement Division filed 405 standalone enforcement actions – the lowest total in...more
11/12/2020
/ Audits ,
Compensation ,
Coronavirus/COVID-19 ,
Custody Rule ,
Disclosure Requirements ,
Fund Transfers ,
Insider Trading ,
Investment Advisers Act of 1940 ,
Misallocation of Funds ,
MNPI ,
Past Performance ,
Private Funds ,
Securities and Exchange Commission (SEC)
On October 23, 2020, the SEC Division of Investment Management’s Chief Accountant’s Office (“IMCAO”) issued three separate “Dear CFO” letters addressing (i) the determination of when a fund commences operations, (ii)...more
The Securities and Exchange Commission (“Commission” or “SEC”) recently instituted settled administrative and cease-and-desist proceedings against a chief compliance officer of a registered investment adviser for record...more