Since our prior IM Update, in separate Alerts, we covered (i) the SEC’s decision to remove from its regulatory agenda proposed rulemakings relevant to the investment management industry, (ii) Ropes & Gray’s updated and...more
On June 11th, 2025, the Securities and Exchange Commission (the “SEC”), together with the U.S. Commodity Futures Trading Commission (the “CFTC”) further extended the compliance date for the amendments to Form PF (the “Form PF...more
On June 11, 2025, the Securities and Exchange Commission and the Commodity Futures Trading Commission voted to extend the compliance date of the Form PF amendments that were adopted in February 2024 again from June 12, 2025...more
On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025....more
The Securities and Exchange Commission (the “SEC”) adopted amendments to Form PF on February 8, 2024. The compliance date for these amendments, which was originally March 12, 2025, was extended to June 12, 2025 (the...more
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
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
As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more
On 7 November 2024, the US Securities and Exchange Commission’s (SEC) Divisions of Examinations, Investment Management, and Enforcement hosted a virtual panel on compliance and enforcement topics as part of its broader...more
The Securities and Exchange Commission will host an open meeting on March 22, 2023 at 10 a.m, which will be open to the public via webcast on the SEC website. The Division of Investment Management will present on Enhancing...more
In recent weeks, the U.S. Securities and Exchange Commission (the “SEC”) has kicked off a wholesale transformation in the regulation of the private funds industry. These actions include rule proposals, enforcement actions,...more