Practical Lessons from the Marketing Rule Sweep
Last week, the U.S. Securities and Exchange Commission announced charges against nine registered investment advisers for holding out hypothetical performance on public websites without adopting
Risk Alert: Assessing Risks, Scoping Examinations, and Requesting Documents
On Wednesday, September 6, 2023, the U.S. Securities and Exchange Commission Division of Examinations released a Risk Alert detailing the Division’s examination selection process. For
John Lukan to Speak at 2023 NSCP National Conference
2023 National NSCP Conference When: October 16-18, 2023 Where: Omni Dallas in Dallas, Texas We are happy to announce our very own our Managing Director,
SEC Adopts Significant Changes to Rules Governing Private Fund Advisers
The SEC not only adopted new rules designed to protect private fund investors this week, but has doubled down and also created a new reporting requirement
SEC Proposes Changes to the Internet Adviser Exemption
On Wednesday, the Securities and Exchange Commission (SEC) proposed amendments to modernize the internet adviser exemption from prohibition on SEC registration for smaller advisers. Investment advisers are
Form N-PX Amendment Reminder
Adopted in November 2022 with a first filing due in August of 2024, the adopted amendments to Form N-PX has flown largely under the radar for
SEC Charges Firm for Disclosure and Policies and Procedures Failures
Last week, the Securities and Exchange Commission (“SEC”) announced the settlement of two enforcement actions relating to disclosure and policies and procedures violations involving two
Risk Alert: Examinations Focused on Additional Areas of the Adviser Marketing Rule
On June 8, 2023, the U.S. Securities and Exchange Commission Division of Examinations released a second Risk Alert concerning amended Rule 206(4)-1 (the “Marketing Rule”).
SEC Continues to Charge Firms with Widespread Recordkeeping Failures
Yesterday, the Securities and Exchange Commission (“SEC”) charged HSBC Securities (USA) Inc. and Scotia Capital (USA) Inc. for widespread failures to maintain and preserve electronic communications in
SEC Adopts Amendments to Enhance Private Fund Reporting
Yesterday, the Securities and Exchange Commission (“SEC”) adopted amendments to Form PF that affect advisers to all private equity funds and large hedge fund advisers.
