News & Analysis as of

Investment Advisers Act of 1940 Enforcement Priorities

Proskauer - The Capital Commitment

SEC v. TZP Management Associates, LLC: Insights Into Private Fund Enforcement Priorities Under Chair Atkins

On August 15, 2025, the Securities and Exchange Commission (“SEC”) issued an order settling proceedings against TZP Management Associates, LLC (“TZP”) for allegedly miscalculating management fee offsets between 2018 and 2023....more

Secretariat

Reflections on Initial SEC Policy Changes Early in the Atkins Era

Secretariat on

Since Paul Atkins became Chairman of the U.S. Securities and Exchange Commission (SEC) on April 21, 2025, the SEC has announced significant pivots in its approaches to enforcement, regulatory guidance, investment adviser...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

Venable LLP

New Certification Requirements on the Horizon for CCOs: Certifying the Efficacy of Compliance Programs at the Conclusion of...

Venable LLP on

On Tuesday, March 22, 2022, Assistant Attorney General Kenneth Polite of the Department of Justice (DOJ) told an audience of compliance professionals that DOJ will direct prosecutors to "consider requiring" chief compliance...more

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