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FinCEN Adopts Final AML Program Rule for Investment Advisers

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more

Private Funds Rules Set to Be Adopted - What to Watch For

The SEC (U.S. Securities and Exchange Commission) has provided notice that it is preparing to adopt the so-called “Private Funds Rules” under the Investment Advisers Act of 1940 (the “Advisers Act”) on August 23, 2023....more

SEC Adopts Proxy Reporting Rule and Form Amendments

The Securities and Exchange Commission (SEC) recently adopted, in a 3-2 vote, rule and form amendments impacting proxy disclosures reporting on Form N-PX (the “amendments”). The amendments that are applicable to mutual...more

SEC Sends Message to Private Fund Sponsors on Audit Obligations Under Custody Rule Through Enforcement Actions

​​​​​​​On September 9, 2022, the SEC announced settlements with nine SEC-registered investment advisers to private funds with respect to alleged violations of Rule 206(4)-2 under the Investment Advisers Act of 1940 (the...more

SEC Proposes ESG Disclosure Rules for Investment Advisers and Investment Companies

On May 25, 2022, the U.S. Securities and Exchange Commission (the “SEC”) proposed a package of new rules to address and enhance investor disclosure practices, and related policies and procedures, regarding Environmental,...more

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