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Investment Adviser Hedge Funds

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for June 2025

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine the following matters: • An SEC settlement with an ex-CEO...more

Carlton Fields

Investment Adviser Hedge Clauses: A Suitable Tool to Limit Liability or an SEC Enforcement Red Flag?

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A “hedge clause,” when incorporated into an investment advisory agreement, is designed to limit an adviser’s liability to its advisory client. Even carefully worded hedge clauses, however, can attract unwanted SEC enforcement...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

Lowenstein Sandler LLP

Alternative Data Poised for More Growth in the Age of AI: The 2024 Lowenstein Sandler Alternative Data Report

Over the last six years, investment management professionals have steadily increased their use of alternative data to improve decision-making, optimize portfolios, improve due diligence, and boost returns. Now, with widely...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

Proskauer Rose LLP

SEC and CFTC Extend Compliance Date for Form PF Amendments

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On January 29, 2025, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (together, the “Agencies”) jointly announced that the compliance date for the new Form PF would be extended by three...more

Winstead PC

Trusts as Qualified Purchasers: Navigating the Qualified Purchaser Threshold for Trusts Investing in Private Securities

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This article is the third and final part in a series discussing trusts in the context of certain common investor thresholds for investment in private securities. This article will examine trusts as “qualified purchases” under...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update October – November 2024

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The following summarizes recent legal developments of note affecting the mutual fund/investment management industry. On October 21, 2024, the SEC Division of Examinations (“EXAMS”) published its annual Examination Priorities...more

Snell & Wilmer

SEC Division of Examinations Priorities for 2025: Examinations Will Prioritize New Rules for Form PF and Regulation S-P, Fiduciary...

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On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued its annual examination priorities for fiscal year 2025. As with its 2024 examination...more

SEC Compliance Consultants, Inc. (SEC³)

Latest SEC Document Request Lists: What Private Fund Managers Should be Worrying About

Many private fund managers are breathing a sigh of relief after the Fifth Circuit struck down the Private Fund Rules (check out our blog post for more information). Do not, however, assume the SEC will stop its aggressive...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for July 2024

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •Judge Paul Engelmayer’s decision on defendants’ motion to...more

Morrison & Foerster LLP

Significant Investment Adviser Regulatory Developments in 2024

Alongside the rapid pace of Securities and Exchange Commission (SEC) rulemaking, the SEC and its Staff continue to shape regulatory obligations for investment advisers in 2024 through guidance, alerts, enforcement actions,...more

Allen Matkins

California's Legislature Mulls Weird Definition Of "Hedge Fund"

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As the California legislature approaches its final recess of the current session, it is continuing to move AB 3129 (Wood), a bill that would according to the bill's digest "require a private equity group or a hedge fund, as...more

Foley Hoag LLP

Fund Managers Must Assess Whether Microsoft/CrowdStrike Outage has Triggered Additional Form PF Filing

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The CrowdStrike computer failures that swept the globe on Friday, July 18, 2024, and persisted through the weekend may have impacted fund advisers relying on the Windows system, possibly triggering an “operations event” that...more

Seward & Kissel LLP

CrowdStrike Outage and its Form PF Implications

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In May 2023, the Securities and Exchange Commission (the “SEC”) adopted amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, requiring, among other things,...more

Morris, Manning & Martin, LLP

Hedge Fund Pitch Deck is an "Advertisement" under the Advisers Act Marketing Rule

Recently, the SEC settled another administrative proceeding under the Advisers Act's Marketing Rule. This time, the SEC focused on advertisements that a hedge fund sponsor made to prospective investors. The hedge fund's...more

Proskauer - The Capital Commitment

Mid-Year Enforcement Update: SEC’s Continued Focus on Private Funds in 2024

As we reach the midpoint of 2024, the SEC has maintained its rigorous enforcement stance on the private funds industry, proposing new rules and oversight tools to better identify and investigate market practices. As 2024...more

Proskauer Rose LLP

Proskauer's Hedge Start: What Key Exemptions Apply to Hedge Funds?

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We have separately discussed the common exemptions from registration of a fund manager with the Securities and Exchange Commission (SEC) as an investment adviser and from registration with the Commodity Future Trading...more

Williams Mullen

SEC Private Fund Rule Struck Down by US Appeals Court

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A U.S. appeals court struck down a newly adopted Securities and Exchange Commission (“SEC”) rule implementing a series of new disclosure requirements and restrictions on private fund advisors....more

Cadwalader, Wickersham & Taft LLP

Big News for Funds June 2024 - Fifth Circuit Strikes Down the Private Fund Adviser Rules

This week, the U.S. Court of Appeals for the Fifth Circuit vacated the private fund advisor rules (the “Final Rule”) adopted by the United States Securities Exchange Commission (the “SEC”). The Final Rule imposed significant...more

Carlton Fields

SEC and CFTC Amend Form PF … Again: Private Fund Advisers Should “Kick the Tires” Before Next Race to File

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In February 2024, the SEC and the Commodity Futures Trading Commission (CFTC) adopted major amendments to Form PF to provide greater transparency into the operations and strategies of private funds, and to assist the...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Proskauer - Private Market Talks Podcast

[Podcast] Private Market Talks: The Hedge Fund Platform Model with Crestline’s Caroline Cooley

In this episode, we’re joined by Caroline Cooley, managing partner and CIO for Crestline Summit Strategies. Caroline joined Crestline in 1998 and has since helped build the firm into a multi-strategy, multi-portfolio and...more

Proskauer Rose LLP

Proskauer's Hedge Start: When Is CFTC Registration Necessary?

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An initial question faced by a new hedge fund manager is whether or not registration with the U.S. Commodity Futures Trading Commission (CFTC) will be required. Limited Trading Exemption - CFTC Rule 4.13(a)(3), which...more

Proskauer Rose LLP

Proskauer's Hedge Start: When Is SEC Registration Necessary?

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An initial question faced by any manager launching a hedge fund is whether or not registration as an investment adviser with the U.S. Secutiries and Exchange Commission (SEC) under the Investment Advisers Act of 1940, as...more

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