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Investment Advisers Act of 1940 Investment Adviser Investors

Troutman Pepper Locke

Supreme Court Denies Certiorari in SEC Disgorgement Case

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On June 6, the U.S. Supreme Court denied the petition for certiorari in the case of Navellier & Associates, Inc. v. Securities and Exchange Commission (SEC). This decision effectively upholds the lower courts’ rulings,...more

Herbert Smith Freehills Kramer

SEC Announces Two Charges for Anti-Money-Laundering Violations

Last week, the Securities and Exchange Commission (SEC) announced two enforcement actions related to the failed implementation of anti-money-laundering (AML) procedures. These charges reflect the SEC’s continued focus on...more

Seward & Kissel LLP

Financial Services Firm Affiliates Settle Five SEC Enforcement Actions for Allegedly Misleading Customers and Failing to Act in...

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Broker Dealers; Compliance Officers; Boards of Directors - Quick Take: The SEC recently settled five separate enforcement proceedings...more

Paul Hastings LLP

SEC Examination Priorities Signal Capital Markets Enforcement

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The Securities and Exchange Commission’s Division of Examinations recently released its 2025 priorities. These identify several new or emerging areas of focus that could be precursors to enforcement actions, such as the use...more

Seward & Kissel LLP

SEC Charges Adviser with Failing to Follow ESG Investment Criteria

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Who may be interested: Registered Investment Companies; Directors of Registered Investment Companies; Investment Advisers - Quick Take: The SEC recently charged a registered investment adviser for alleged misstatements and...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

Vedder Price

SEC Settles Enforcement Proceedings Against Adviser for Allegedly Misleading Investors Regarding Its Investment Strategy

Vedder Price on

On September 19, 2024, the SEC announced the settlement of administrative proceedings brought against a registered investment adviser for allegedly making misleading statements regarding how it managed investments for clients...more

Carlton Fields

SEC Penalties for Off-Channel Communications: Still Blowing in the Wind

Carlton Fields on

The SEC has increased its enforcement efforts against firms that are registered as broker-dealers and/or investment advisers for alleged violations of federal securities laws involving “off-channel communications.” Such...more

Seward & Kissel LLP

SEC Charges Crypto Firm with Custody Rule Violations and Misleading Fund Investors on the Timing of Redemption Notices

Seward & Kissel LLP on

On September 3, 2024, the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against Galois Capital Management LLC (“Galois”), a Florida-based former registered investment adviser, for failing to...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for August 2024

More Flack on WhatsApp, Hypothetical Performance SmackDown, A Timely Warning on the Pay-to-Play Rule, and Updates to Qualifying Venture Capital Fund Exemption - This month's big news from the SEC was more piggy-bank breaking...more

Woodruff Sawyer

Insurance Expense Allocation for Investment Managers: A Primer

Woodruff Sawyer on

Now that the Private Fund Adviser Rules have been chucked into the dustbin of history, should investment advisers expect the SEC staff to give them the benefit of the doubt on expense allocation? Not likely. This is a...more

DarrowEverett LLP

Fifth Circuit Puts the Brakes on SEC’s Private Fund Rules: What’s Next For Private Fund Advisers

DarrowEverett LLP on

In a continuation of recent court decisions overturning the rulemaking authority of federal agencies, a recent decision by the U.S. Court of Appeals for the Fifth Circuit vacated the Securities and Exchange Commission’s (SEC)...more

Warner Norcross + Judd

Private Fund Adviser Rule Vacated

On June 5, 2024, the U.S. Court of Appeals for the Fifth Circuit (the “court”) vacated the private fund adviser rule (the “rule”) adopted by the Securities and Exchange Commission (SEC) in September 2023. Notably, during the...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for June 2024

Private Fund Rules Cancelled, Survey Says Marketing Rule is a Lot of Work and the Intersection of Regulation BI and Investment Adviser’s Fiduciary Duty - Welcome to our June Regulatory Roundup, where we provide you with a...more

Cooley LLP

FAQs on SEC’s Private Fund Adviser Rules After Fifth Circuit Decision

Cooley LLP on

As most fund managers have likely heard by now, on June 5, 2024, the US Court of Appeals for the Fifth Circuit vacated the private fund adviser rules that the Securities and Exchange Commission (SEC) adopted in summer 2023,...more

Morrison & Foerster LLP

Fifth Circuit Vacates SEC Private Fund Adviser Rules

On June 5, 2024, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) unanimously vacated the “Private Fund Adviser Rules,” which the U.S. Securities and Exchange Commission (the SEC)...more

Herbert Smith Freehills Kramer

Fifth Circuit Vacates SEC Rule Regulating Private Funds Advisers

In a highly anticipated opinion, the Fifth Circuit announced on June 5, 2024 its decision to vacate rules adopted by the Securities and Exchange Commission (SEC or the Commission) in 2023 (collectively, the Rule) that would...more

Orrick, Herrington & Sutcliffe LLP

5th Circuit vacates SEC private fund adviser rule

On June 5, the U.S. Court of Appeals for the Fifth Circuit vacated an SEC rule that represented a significant change in how private funds and their fund advisers are regulated. As it stands, the decision will spare private...more

Morgan Lewis

Fifth Circuit Vacates SEC Private Fund Adviser Rules in Full

Morgan Lewis on

In a unanimous decision published on June 5, 2024, the US Court of Appeals for the Fifth Circuit vacated the entire set of regulations, including amendments to existing rules (collectively, the Rules), adopted by the US...more

Robinson Bradshaw

Fifth Circuit Vacates Private Fund Adviser Rules

Robinson Bradshaw on

Yesterday, a three-judge panel of the United States Court of Appeals for the Fifth Circuit unanimously vacated the Private Fund Adviser Rules adopted by the Securities and Exchange Commission (which we previously summarized)...more

Vedder Price

Fifth Circuit Vacates Private Fund Adviser Rules

Vedder Price on

In a 3-0 decision, the Fifth Circuit Court of Appeals vacated the SEC’s private fund adviser rules (“Final Rule”). Each component of the Final Rule was vacated, including the Private Fund Audit Rule, Private Fund Quarterly...more

Katten Muchin Rosenman LLP

Vacation Alert: Fifth Circuit Vacates Private Fund Adviser Rules

On June 5, the Fifth Circuit Court of Appeals (Court) vacated the entire set of private fund adviser rules adopted by the Securities and Exchange Commission (SEC) on August 23, 2023. Many private fund advisers would have been...more

Alston & Bird

Fifth Circuit Overturns SEC Private Funds Rules

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Our Investment Funds Team reviews the implications of the Fifth Circuit’s decision to vacate the Securities and Exchange Commission’s Private Funds Rules....more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

U.S. Court of Appeals Invalidates SEC’s Private Fund Adviser Rules

On June 5, the U.S. Court of Appeals for the Fifth Circuit vacated the U.S. Securities and Exchange Commission’s (“SEC”) 2023 Private Fund Advisers Rule (“Final Rules”), agreeing with petitioners that the SEC exceeded its...more

Morris, Manning & Martin, LLP

SEC Scrutinizes Private Fund Investor Communications

There has been much ink spilled over the Marketing Rule and the Private Fund Rule under the Investment Advisers Act of 1940.  These rules represent significant regulation of investment advisers, imposing specific affirmative...more

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