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Enforcement Actions Private Funds Investment Management

Blank Rome LLP

Regulatory Update and Recent SEC Actions, July 2025

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Recent SEC Administration Changes - SEC Names Brian Daly as Director of the Division of Investment Management - On June 10, 2025, the Securities and Exchange Commission (the “SEC”) announced that Natasha Vij Greiner,...more

Proskauer - The Capital Commitment

SEC Regulation in a Non-Regulatory Environment

With Paul Atkins as the new SEC Chair, the agency’s priorities have shifted away from many of the aggressive policies of former Chair Gensler. The first four months of the Republican controlled SEC saw a dramatic shift in the...more

Proskauer - The Capital Commitment

Regulatory Scrutiny on Potential MNPI in the Credit Markets

Over the past year, regulatory scrutiny of the credit markets has intensified, with the SEC investigating the potential use of material nonpublic information (“MNPI”) relating to credit instruments. The SEC brought a number...more

DLA Piper

IMpact: Investment Management News - Q2 2025

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Welcome to IMpact: Investment Management News. In this regular bulletin, DLA Piper lawyers share their insights on key developments that are impacting the investment management industry. Pursuant to rules issued in 2024 and...more

Carlton Fields

Builder of Investment Models Deviates From Blueprints - Employee’s Rogue Remodeling Costs Builder Plenty

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The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered investment advisers Two Sigma Investments LP and Two Sigma Advisers LP illustrates significant risks for investment...more

SEC Compliance Consultants, Inc. (SEC³)

February and March 2025 Regulatory Roundup

SEC Clarifies Marketing Rule, Warms up to Crypto and Private Placements under 506(c), and Backs off Form SHO; Latest Lessons from EXAMS: Duty of Care and Risk Identification Failures - Welcome to our February and March 2025...more

SEC Compliance Consultants, Inc. (SEC³)

Predictions for 2025: What Private Fund Advisers Can Expect from SEC Examinations

There has been a lot of conjecture that the SEC may become friendlier to registrants because of the new administration. Given the SEC’s mandate to protect the investing public, however, we do not expect SEC examiners to...more

Winstead PC

SEC Renewed Action on Hedge Clauses

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Hedge clauses are provisions in investment advisory agreements that aim to limit an adviser’s liability for certain actions or outcomes. The U.S. Securities and Exchange Commission (the “SEC”) has expressed the position that...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Morgan Lewis

Current Developments in SEC Enforcement for Private Funds and a Look Ahead 2024–2025

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In 2024, private funds continued to be a major focus for the US Securities and Exchange Commission (SEC), with an active docket of enforcement cases and rulemaking efforts. Although we expect 2025 to include a continued...more

Proskauer - The Capital Commitment

Top Ten Regulatory and Litigation Risks for Private Funds in 2024

To understand the litigation and regulatory risks that are coming in 2024 for private capital, it is helpful to look back briefly on recent events. Arguably, the single most important event over the last 18 months was the...more

Lowenstein Sandler LLP

The SEC’s Private Fund Adviser Rules Explained — Part 1: The Restricted Activities Rule

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On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) adopted new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act), to address what it perceives as certain conflicts...more

Morgan Lewis

Current Developments in Sec Examinations & Enforcement: a Special Report for Private Funds

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Morgan Lewis’s securities enforcement and investment management teams highlight expected US Securities and Exchange Commission (SEC or Commission) priorities for private fund managers in 2022 and look back at SEC private fund...more

Proskauer Rose LLP

Private Fund Managers – 2021 SEC Enforcement Results and What to Expect Next

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For much of 2021, the SEC has been in transition. New Enforcement staff have been settling into their roles since April of 2021, when Gary Gensler was confirmed and sworn in as Chair of the SEC. Under former Chairman Jay...more

Troutman Pepper Locke

Investment Management and Private Funds Roundtable: TALF 2020 and PPP Update

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Pepper Hamilton partner Gregory J. Nowak recently held a virtual Investment Management and Private Funds Roundtable. Mr. Nowak was joined by Genna Garver, partner at Troutman Sanders, to discuss a variety of current topics,...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

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