News & Analysis as of

Investment Advisers Act of 1940 Securities and Exchange Commission (SEC) Venture Capital

Cooley LLP

Updated Marketing Rule FAQ Relieves Fund Managers From Calculating Investment-Level Net Returns

Cooley LLP on

On March 19, 2025, staff from the Securities and Exchange Commission (SEC staff) updated its prior guidance regarding the requirement to show net returns of an individual investment, or subset of investments, in compliance...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

Cooley LLP

Facing the SEC’s New Rules for Venture Capital and Other Private Fund Advisers

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Just over a month ago, the Securities and Exchange Commission (SEC) adopted new rules for venture capital (VC) and other private fund advisers under the Investment Advisers Act of 1940 (Advisers Act). These new rules, which...more

Morrison & Foerster LLP

Marketing Private Funds to U.S. Investors — A Practical Guide for Asia-Based Managers

As the private equity (“PE”) and venture capital (“VC”) funds industry grows and matures in Asia, managers are increasingly looking to market interests in their funds to U.S.-based investors. However, many Asia-based managers...more

Goodwin

Exempt Reporting Advisers Faced Significantly More SEC Enforcements in 2022

Goodwin on

The Securities and Exchange Commission (SEC) brought an unusually high number of enforcement actions against exempt reporting advisers in 2022 — that appears to be more than the prior three years combined and a record number...more

Foley Hoag LLP

SEC Amends “Accredited Investor” Definition

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On August 26, 2020, the Securities and Exchange Commission (“SEC”) amended the definition of “accredited investor,” one of the principal tests for determining eligibility for participation in private placements of securities....more

Troutman Pepper Locke

SEC Amends “Accredited Investor” Definition

Troutman Pepper Locke on

On August 26, the U.S. Securities and Exchange Commission (SEC) adopted amendments expanding the definition of “accredited investor” to allow additional categories of investors to invest in unregistered private offerings. The...more

Proskauer Rose LLP

Volcker Rule Amendments: Implications for Asset Managers

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On June 25, 2020, the Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the "Agencies") adopted amendments (the "Amendments") to the regulations implementing section 13 of the Bank Holding Company...more

Orrick - Finance 20/20

Securities and Exchange Commission Adopts Final Rule That Provides New Exemptions From Investment Adviser Registration for...

Orrick - Finance 20/20 on

On January 5, 2018, the SEC adopted amendments to Rule 203(l)-1 under the Investment Advisers Act of 1940 (the “Advisers Act“) that defines a “venture capital fund” and Rule 203(m)-1 under the Advisers Act that implements the...more

Herbert Smith Freehills Kramer

Funds Talk: June 2017 - SEC Proposes Changes to Investment Advisers Act in Response to FAST Act

On May 3, the Securities and Exchange Commission (SEC) released proposed amendments to certain rules under the Investment Advisers Act of 1940 (the Advisers Act) to reflect the impact of the Fixing America’s Surface...more

Foley & Lardner LLP

A Compilation of Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - Amendments to the Venture Capital Fund Adviser and Private Fund Adviser Exemptions - Last month the SEC’s Division of Investment Management issued a guidance update (Update) addressing recent...more

Dorsey & Whitney LLP

Fund Founder, Chief Legal Officer and Controller Sanctioned by SEC

Dorsey & Whitney LLP on

The founder of a venture capital fund, assisted by its chief legal officer and controller, took more money from the fund as “advanced fees” than was actually due and owing. The money was used for other entities in the...more

Proskauer Rose LLP

SEC Issues Interpretive Guidance on the Venture Capital Fund Adviser Exemption

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On December 2, 2013, the SEC's Division of Investment Management issued a new "Guidance Update" that provides some important interpretive guidance on the exemption from registration under the Investment Advisers act of 1940...more

Broker-Dealer Compliance + Regulation

SEC Staff Elaborates on Venture Capital Adviser Exemption

The SEC’s Division of Investment Management provided advisers to venture capital funds with guidance on fund structures that do not jeopardize an adviser’s ability to rely on the exemption from registration provided by...more

Stinson - Corporate & Securities Law Blog

SEC Gives Guidance On Venture Capital Exemption

The SEC Division of Investment Management has provided guidance regarding the application of the exemption from investment adviser registration available to an investment adviser that advises solely one or more “venture...more

Foley Hoag LLP

SEC Offers Custody Rule Relief to Venture Capital and Private Equity Funds

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Following the adoption of the Dodd-Frank Act and amendments to the rules under the Investment Advisers Act of 1940 (the “Advisers Act”) adopted by the SEC, many previously unregistered managers to private funds, including...more

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