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Overview of New Private Fund Rules' Scope and Compliance Dates

The SEC recently adopted new rules (the “Private Fund Rules”) that will require additional reporting requirements and impose restrictions on certain activities of investment advisers to private funds (“Private Funds”). While...more

Attn: RIAs Charging Performance-Based Fees, Thresholds for “Qualified Client” Increased by $100K

The Investment Advisers Act of 1940, as amended (the “Advisers Act”), generally prohibits SEC‑registered investment advisers (“RIAs”) from entering into an advisory contract that charges a performance fee to a client who is...more

SEC Sharpens Focus on RIA Compliance Programs, Part 2

In November 2020, the staff of the SEC’s Division of Examinations (f.k.a. OCIE) (the “Examinations Division” and its staff, “Examinations Staff”) issued two risk alerts (the “Alerts”) that, in our view, offer particularly...more

SEC Risk Alert Provides Electronic Messaging Guidance to RIAs

The SEC’s Office of Compliance Inspections and Examinations (the “OCIE”) recently issued a risk alert (the “Alert”) regarding electronic messaging by registered investment advisers (“RIAs”). As used in the Alert, the term...more

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