On June 5th, 2024, the United States Court of Appeals for the Fifth Circuit (the “Court”) vacated the U.S. Securities and Exchange Commission’s (“SEC’s”) private fund advisers rules (the "Rules"), which would have imposed...more
On May 13, 2024, the U.S. Securities and Exchange Commission’s Division of Investment Management (“SEC”) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint proposal...more
On July 21, 2021, the Securities and Exchange Commission (the “SEC”), Division of Examinations (the “Division”), issued new guidance regarding “Fixed Income Principal and Cross Trades by Investment Advisers from an...more
The New York State Department of Law recently adopted regulations (“NY IAR Regs”) that, starting February 1, 2021, require Investment Adviser Representatives (“IAR”) representing a New York state registered investment adviser...more
On December 22, 2020, the SEC finalized rules governing investment adviser marketing and payments to solicitors under the Investment Advisors Act of 1940, as amended. The reforms create a single rule to replace the current...more
The US Securities and Exchange Commission (SEC) has proposed to amend and modernize certain rules under the Investment Advisers Act that deal with investment adviser advertising and payments to solicitors. The proposed...more
On June 23rd, the Office of Compliance Inspections and Examinations (“OCIE”)? released a Risk Alert, Observations from Examinations of Investment Advisers Managing Private Funds (the “Risk Alert”), detailing certain...more
On March 13, 2020, the Securities and Exchange Commission (the “SEC”) announced two releases providing regulatory relief for investment funds and investment advisers whose operations may be impacted by COVID-19. In announcing...more
On August 21, 2019, the Securities and Exchange Commission (the “SEC”) issued guidance relating to the proxy voting responsibilities of investment advisers (the “Proxy Voting Guidance”). This guidance follows the SEC’s...more
On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted to adopt two new rules intended to protect retail investors. ...more
On Wednesday, June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted to adopt requirements for investment advisers and broker-dealers to prepare and file a Form CRS Relationship Summary. The Form CRS...more
Investment Advisers Act Rule 206(4) (the “Custody Rule”) is designed to protect client funds and securities from being lost, misused, or otherwise misappropriated by investment advisers. As such, the Custody Rule provides...more
The Office of Compliance Inspections and Examinations (the “OCIE”) published a Risk Alert on September 14, 2017 discussing the most frequent issues that the OCIE observed during its examinations of investment advisers with...more
On August 25, 2016, the Securities and Exchange Commission (the “SEC”) adopted amendments to rules promulgated under the Investment Advisers Act of 1940 (the “Advisers Act”) and the investment adviser registration and...more