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Private Funds Investment Management

Seward & Kissel LLP

SEC Eliminates Longstanding Limits on Registered Closed-End Funds Providing Retail Investors with Increased Access to Private...

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The Securities and Exchange Commission (the “SEC”) staff recently announced that the Division of Investment Management (the “Division”) will no longer require registered closed-end funds that invest in private funds...more

Alston & Bird

SEC Formalizes and Expands Guidance Increasing Retail Access to Private Funds

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Our Investment Funds Team explains the Securities and Exchange Commission new guidance that expands retail investor access to private funds by relaxing previous restrictions....more

Akin Gump Strauss Hauer & Feld LLP

SEC Staff Announces Reversal of Policy Limiting Retail Access to Registered Funds of Funds

On August 15, 2025, the staff of the SEC’s Division of Investment Management (the “Staff”) published a new Accounting and Disclosure Information (“ADI”) regarding registered closed-end funds of private funds (“CE-FOPFs”)....more

Ropes & Gray LLP

SEC Issues New Guidance for Registered Closed-End Funds Investing in Private Funds

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As previously described in a May Ropes & Gray Alert, the SEC staff no longer requires retail closed-end funds to limit their investments in private funds – i.e., funds relying upon Sections 3(c)(1) or 3(c)(7) of the 1940 Act...more

Morrison & Foerster LLP

SEC Rescinds Staff Position Limiting Registered Closed-End Funds’ Investments in Private Funds

On August 15, 2025, the Division of Investment Management (the “Division”) of the U.S. Securities and Exchange Commission (SEC) published Accounting and Disclosure Information 2025-16 (ADI), providing updated guidance for...more

Seward & Kissel LLP

SEC Lifts 15% Limit on Private-Asset Holdings for Registered Closed-End Funds that Invest in Private Funds

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Who may be interested: Registered Closed-End Funds, Registered Investment Advisers, Compliance Staff, Boards of Directors, Broker-Dealers, Private Fund Managers - Quick Take: The Securities and Exchange Commission (the...more

Troutman Pepper Locke

Conversation with Former SEC Chief Economist Dr. Jessica Wachter on Investment Management Rulemaking at the Commission – PE...

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This episode of PE Pathways features Dr. Jessica Wachter, former chief economist and director of the Division of Economic and Risk Analysis at the Securities and Exchange Commission (SEC), now a professor in quantitative...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions, July 2025

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Recent SEC Administration Changes - SEC Names Brian Daly as Director of the Division of Investment Management - On June 10, 2025, the Securities and Exchange Commission (the “SEC”) announced that Natasha Vij Greiner,...more

Goodwin

Further Reform for UK Private Fund Managers: The Government’s Road Map for Growth in Financial Services

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On 15 July 2025, Chancellor of the Exchequer Rachel Reeves delivered her Mansion House 2025 speech unveiling the Leeds Reforms, a programme for financial services reforms to drive investment and growth in the sector....more

Ropes & Gray LLP

Negotiating Economics: What are the Different Advantages of Co-Investment for GPs and LPs?

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GPs are increasingly exploring formalised co-investment structures in a bid to secure management fees and carried interest. Co-investment activity has increased fivefold over the past two decades, hitting a record $33.2...more

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

Eversheds Sutherland (US) LLP

SEC raises ceiling on closed-end funds’ investments in private funds

Recent policy initiatives and remarks from leaders of the US Securities and Exchange Commission (SEC) have created a changing landscape for retail access to the private markets. At a recent conference hosted by the Practising...more

Walkers

Raising platforms optimising Guernsey vehicles for investment platforms and fund structuring

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The use of Guernsey umbrella structures for both regulated and unregulated investment structures has seen a notable rise over the past 18 months. Where these structures have typically been used for larger, master fund/...more

Ropes & Gray LLP

Supreme Court to Consider Closing a Back Door to Fund Litigation Claims Under the Investment Company Act

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On June 30, the U.S. Supreme Court agreed to hear a case that will determine whether Section 47(b) of the Investment Company Act of 1940 (ICA) creates a private right of action for shareholders of registered investment...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update April – June 2025

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Since our prior IM Update, in separate Alerts, we covered (i) the SEC’s decision to remove from its regulatory agenda proposed rulemakings relevant to the investment management industry, (ii) Ropes & Gray’s updated and...more

Woodruff Sawyer

Expanding Retail Investor Access to Private Funds: A Spider-Man Problem

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Private funds could be facing a Spider-Man problem. Let me explain. Because he was bitten by a radioactive spider, Spider-Man has superpowers. He can jump really high. He can shoot webs from his hands. When his...more

Seward & Kissel LLP

An Introduction to Rated Note Feeders

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In today’s evolving investment landscape, institutional investors are increasingly seeking innovative structures that align with regulatory requirements while maximizing returns. One such structure gaining traction is the...more

Morgan Lewis

Japan Continues to Relax Registration Requirements – Simplified Type 1 FIBO Registration

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Japanese regulators have been significantly amending the Financial Instruments and Exchange Act (FIEA), similar to other jurisdictions seeking to innovate and relax regulatory requirements in order to help spur economic...more

Proskauer - The Capital Commitment

Three Risks to Monitor in Private Credit

Private credit has become an essential source of financing globally, with fund sponsors enjoying strong demand from borrowers, market participants, and investors.  However, as the industry’s “golden age” continues, regulatory...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

Proskauer - The Capital Commitment

Regulatory Scrutiny on Potential MNPI in the Credit Markets

Over the past year, regulatory scrutiny of the credit markets has intensified, with the SEC investigating the potential use of material nonpublic information (“MNPI”) relating to credit instruments. The SEC brought a number...more

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

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On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more

Seward & Kissel LLP

Extension of Form PF Amendments Compliance Date

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On June 11th, 2025, the Securities and Exchange Commission (the “SEC”), together with the U.S. Commodity Futures Trading Commission (the “CFTC”) further extended the compliance date for the amendments to Form PF (the “Form PF...more

Akin Gump Strauss Hauer & Feld LLP

SEC and CFTC Again Extend Compliance Deadline for Form PF Amendments

On June 11, 2025, the Securities and Exchange Commission and the Commodity Futures Trading Commission voted to extend the compliance date of the Form PF amendments that were adopted in February 2024 again from June 12, 2025...more

Proskauer - Regulatory & Compliance

SEC Further Extends Form PF Compliance Date and Signals Broader Reconsideration

On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025....more

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