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Investment Advisers Act of 1940 Investment Regulatory Reform

Secretariat

Reflections on Initial SEC Policy Changes Early in the Atkins Era

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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

Moore & Van Allen PLLC

Acting Chairman Uyeda Suggests Revisiting the Role of State Securities Regulators in Connection with Mid-size Investment Advisers...

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On April 8, 2025, then Acting Chairman Mark T. Uyeda of the U.S. Securities and Exchange Commission (“SEC”), highlighted in remarks before the Annual Conference on Federal and State Securities Cooperation two areas where...more

Goulston & Storrs PC

Need to Know: SEC’s New Private Fund Rules

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The Securities and Exchange Commission (“SEC”) recently adopted sweeping new rules (the “Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”) that include significant changes governing how private...more

Sullivan & Worcester

SEC Adopts Amendments to the Investment Company Names Rule (Rule 35d-1)

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On September 20, 2023, the Securities and Exchange Commission (“SEC”) adopted amendments to Rule 35d-1[1] (the “Names Rule”) under the Investment Company Act of 1940, as amended (“1940 Act”), as well as amendments to certain...more

Akerman LLP

The SEC’s Newly Adopted Rules and Rule Amendments for Private Fund Advisers

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On August 23, 2023, the Securities and Exchange Commission (the SEC) adopted new rules and rule amendments (collectively, the “Rules”) under the Investment Advisers Act of 1940, as amended (the Advisers Act) to enhance the...more

Seyfarth Shaw LLP

An Early Glimpse into the SEC’s Private Funds Advisor Rule

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The Securities and Exchange Commission (SEC) has adopted the long awaited “Private Fund Adviser Rule” (the “PFA”). The proposed PFA was introduced on February 9, 2022 (“Proposed Rule”), and the SEC has been working with the...more

Proskauer - The Capital Commitment

Conflicts of Interest: How High Will the Bar be Raised?

The SEC last month proposed rules under the Advisers Act indicating a dramatic shift in how the SEC intends to reduce conflicts of interest involving private fund managers and their investors. As we previously noted in the...more

Polsinelli

SEC Proposes Expanding the Definitions of “Accredited Investor” and “Qualified Institutional Buyer”

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On December 18, the U.S. Securities and Exchange Commission (“SEC”) issued a proposal to update the definition of “accredited investor” pursuant to Rule 506 of Regulation D under the Securities Act of 1933 (“Securities Act”)...more

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