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On this Ropes & Gray podcast, Alyssa Horton and Colleen Meyer, both counsel in the private funds regulatory group, explore the recent SEC staff guidance on the Marketing Rule. They discuss the new FAQs issued on March 19,...more
On March 19, 2025, the Securities and Exchange Commission’s (SEC) Division of Investment Management staff (Staff) issued two new Frequently Asked Questions (FAQs) focused on Rule 206(4)-1 under the Investment Advisers Act of...more
On March 19, 2025, the staff of the Securities and Exchange Commission (SEC) updated the FAQ page pertaining to Rule 206(4)-1 (the Marketing Rule) under the Investment Advisers Act of 1940. The updated guidance permits...more
On March 19, 2025, the Securities and Exchange Commission (“SEC”) updated its frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). The new FAQs permit...more
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
On March 19, 2025, the SEC Staff published two Marketing Rule FAQs that address some of the more challenging aspects of the Marketing Rule requirement to present net performance information. Specifically, the FAQs provide a...more
On March 19, 2025, the Securities and Exchange Commission’s (SEC) Division of Investment Management updated its Marketing Compliance Frequently Asked Questions (FAQ) to address industry confusion that has arisen in the wake...more
On March 19, 2025, the staff of the SEC’s Division of Investment Management issued two new FAQs related to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Rule”). The new guidance reduces the complexity of the...more
On March 19, 2025, the staff of the U.S. Securities and Exchange Commission (the “SEC”) updated its Frequently Asked Questions (“FAQ”) pertaining to Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of...more
The SEC's Division of Investment Management (Division) on March 19, 2025, updated its Marketing Compliance Frequently Asked Questions (FAQs) with respect to Rule 206(4)-1 under the Investment Advisers Act of 1940 (Marketing...more
The FAQs provide investment advisers greater flexibility to present investment performance solely on a gross basis. On March 19, 2025, the Securities and Exchange Commission (SEC or the Commission) Staff released two new...more
New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes Rule Changes for Proxy Advisory Firms – On November 5, 2019, the SEC issued a release proposing amendments to the federal proxy rules...more
SEC Sanctions Private Fund Adviser and Chief Investment Officer for Valuation Policy Failures - On June 4, 2019, the SEC announced that Deer Park Road Management Company, LP (“Deer Park”) agreed to pay a $5 million...more
The U.S. Securities and Exchange Commission (SEC) held an open meeting on August 21, 2019, (the Open Meeting) and approved two items: (1) guidance regarding the proxy voting responsibilities of investment advisers under the...more
On February 21, 2017, the SEC's Division of Investment Management provided additional guidance with respect to Rule 206(4)-2 under the Investment Advisers Act of 1940, as amended (the Custody Rule). The guidance addressed the...more