On March 19, the SEC issued updates to its FAQs regarding compliance with Rule 206(4)-1 of the Advisers Act (the Marketing Rule) addressing (i) when gross and net performance are required for certain “extracted” performance,...more
Trump Picks New SEC Head, SEC Enforcement Starts Strong in 2025, and Latest Lessons from EXAMS: Details Matter and Duty of Care Fails - Welcome to our January 2025 Regulatory Roundup, where we provide practical advice on the...more
In early February 2024, the Commodities Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) announced new disclosure rules. These rules will apply to hedge funds and to managers of other private...more
REGULATORY UPDATES - Recent SEC Leadership Changes - The Securities and Exchange Commission (the “SEC”) announced the appointment of Deborah J. Jeffrey as Inspector General effective May 7, 2023. Prior to this...more
On May 3, 2023, the Securities and Exchange Commission (SEC) adopted amendments to Form PF. Form PF is the “confidential reporting form for certain SEC-registered investment advisors to private funds” that “provides the...more
Private funds can draw lessons about how to prioritize their compliance efforts and practices in response to a series of warnings by newly-appointed federal regulators of increased scrutiny, regulation, and enforcement...more
On January 26, 2022, the U.S. Securities and Exchange Commission (SEC) issued proposed amendments to Form PF, which is the confidential reporting form for certain registered investment advisers to private funds. The proposed...more
Recent days have offered us a couple of data points indicating that the private fund disclosure regime is under review at the SEC and that this review is a priority at the agency....more