News & Analysis as of

Investment Adviser Reporting Requirements

Fenwick & West LLP

FinCEN Delays Investment Adviser AML/CFT Rule to January 2028: What Fund Managers Should Know

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of its 2024 investment advisor AML rule for registered investment...more

Wilson Sonsini Goodrich & Rosati

Treasury Postpones Effective Date of Investment Adviser AML Rule, Plans Revisions

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced that it intends to postpone the effective date of the final rule establishing anti-money laundering (AML) and suspicious...more

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Delays Effective Date of Investment Adviser Rule and Intends to Revisit the SEC Customer Identification Program Rule for...

In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...more

Seward & Kissel LLP

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

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On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...more

Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Procopio, Cory, Hargreaves & Savitch LLP

When Must Private Fund Managers File as an Exempt Reporting Adviser in California?

Some private fund managers in California face potentially dire consequences if they fail to properly register with the state and the U.S. Securities and Exchange Commission (SEC). Failing to adhere to relevant securities laws...more

Mayer Brown

BREAKING: FinCEN Postpones Effective Date of Investment Adviser AML Rule

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Earlier yesterday, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the...more

A&O Shearman

FCA publishes final rules on data decommissioning

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The UK Financial Conduct Authority (FCA) has published final policy statement PS25/7, alongside an updated webpage, on data decommissioning. Following the FCA's consultation in April, it has proceeded with: - Removing the...more

Dorsey & Whitney LLP

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

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On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...more

Lowenstein Sandler LLP

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

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On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

A&O Shearman

FCA publishes consultation on streamlining data collection requirements

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The UK Financial Conduct Authority (FCA) has published a consultation paper (CP) proposing the removal of reporting and notification requirements as part of its strategy to prevent unnecessary collection of data to reduce...more

Seward & Kissel LLP

SEC Extends Effective and Compliance Dates for Amendments to Investment Company Reporting Requirements

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Compliance Officers - Quick Take: The SEC announced a two-year extension to the effective and compliance dates for rule amendments...more

DLA Piper

SEC Clarifies When Gross-Only Performance May Be Permissible

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The US Securities and Exchange Commission staff (Staff) has issued revised guidance regarding the application of Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (Marketing Rule), providing flexibility for...more

Morris, Manning & Martin, LLP

"Custody" for Registered Investment Advisers in Unusual Circumstances

For most registered investment advisers (RIAs), their annual update to Form ADV will be due on March 31, 2025. We have received several questions about “custody” and peculiar situations where RIAs may inadvertently have...more

Vedder Price

Investment Services Regulatory Update: February 2025

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NEW AND PROPOSED RULES - Third Set of Form PF Amendments to Take Effect on June 12, 2025 - Attorneys in Vedder Price’s Investment Services Group recently published a bulletin, available here, on the third set of...more

Morgan Lewis

FINRA Proposes Single Rule to Replace FINRA Rules 3270 and 3280

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FINRA has proposed a single, streamlined rule (the Proposed Rule) to replace FINRA Rule 3270 (Outside Business Activities of Registered Persons) and FINRA Rule 3280 (Private Securities Transactions of an Associated Person)...more

DLA Piper

Chile: Comisión Para el Mercado Financiero Crea el Manual de Sistemas de Información de Fondos

DLA Piper on

El 28 de febrero de 2025, la Comisión para el Mercado Financiero (CMF) emitió la Norma de Carácter General N°532 (NCG 532), que crea el Manual de Sistemas de Información de Fondos y establece la forma, periodicidad y medio a...more

DLA Piper

Chile: Financial Market Commission creates its Fund Information Systems Manual

DLA Piper on

On February 28, 2025, Chile’s Financial Market Commission (CMF, for its Spanish translation) issued General Rule No. 532 (NCG 532), which creates a Fund Information Systems Manual and establishes the form, frequency, and...more

Troutman Pepper Locke

FUNDamentals: Form N-PX — Institutional Investment Managers Must File, Even if No ‎Proxies Were Voted

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With Form ADV annual updating amendments due for many investment advisers by the end of next month, advisers should consider whether to update their proxy voting policies and related disclosure in Part 2A, Item 17 in light of...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update December 2024 – January 2025

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On February 7, 2025, the SEC issued an order postponing compliance requirements with Rule 13f-2 under the Securities Exchange Act and reporting requirements on Form SHO. As a result, initial Form SHO reports from...more

Morgan Lewis

Temporary Reprieve for New Short Sale Reporting on Form SHO; Filings not Due Until 2026

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The date for complying with new Rule 13f-2 and filing Form SHO has been extended by one year. The first filings by covered institutional investment managers will now be due February 17, 2026, rather than February 14, 2025....more

Paul Hastings LLP

SEC Reporting Obligations Under Section 13 and Section 16 of the Exchange Act - UPDATED February 2025

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This legal update summarizes (a) the reporting requirements under Section 13(d), (f), (g) and (h) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), which are generally applicable to persons that own or...more

SEC Compliance Consultants, Inc. (SEC³)

The Most Wonderful Time of the Year: Form ADV Season

For most investment advisers, March signals the beginning of Form ADV season, where compliance officers gather all kinds of firm data to update a document fraught with potential regulatory liability. For the uninitiated, Form...more

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