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Proskauer Rose LLP

SEC Chairman Paul Atkins to Urge SEC to Rethink Private Fund 15% Threshold

Proskauer Rose LLP on

On May 19, 2025, the Securities and Exchange Commission’s (the “SEC”) Chairman Paul Atkins delivered prepared remarks before the SEC Speaks Conference hosted by the Practicing Law Institute (PLI). In his remarks, Atkins...more

Carlton Fields

Investment Adviser Hedge Clauses: A Suitable Tool to Limit Liability or an SEC Enforcement Red Flag?

Carlton Fields on

A “hedge clause,” when incorporated into an investment advisory agreement, is designed to limit an adviser’s liability to its advisory client. Even carefully worded hedge clauses, however, can attract unwanted SEC enforcement...more

Herbert Smith Freehills Kramer

SEC Accredited Investor Proposal Could Yield New Product Opportunities for Private Fund Managers

On Dec. 18, 2019, the Securities and Exchange Commission (SEC or Commission) proposed amendments to broaden the definition of “Accredited Investor” under Regulation D to cover a broader group of investors, including adding...more

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