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Section 13 and 16 Developments: Lessons Learned from Recent SEC Enforcement Actions

Over the past year, the U.S. Securities and Exchange Commission (“SEC”) has intensified its focus on beneficial ownership reporting under Sections 13(d), 13(g) and 16(a) of the Securities Exchange Act of 1934 (“Exchange...more

SEC Continues Focus on Off-Channel Communications

On August 14, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain...more

5th Circuit Strikes Down Private Fund Adviser Rules

On June 5, 2024, The United States Court of Appeals for the Fifth Circuit (Fifth Circuit) vacated new rules applicable to advisers to private funds1 recently enacted by the Securities and Exchange Commission (SEC). These...more

SEC Modernizes Internet Adviser Rule

On March 27, 2024, the Securities and Exchange Commission ("SEC") adopted amendments to the rule allowing internet-based investment advisers to register with the SEC instead of with states (the "internet adviser exemption")....more

SEC Lists Crypto and Information Security Among its 2024 Examination Priorities

On October 16, 2023, the US Securities and Exchange Commission ("SEC") Division of Examinations ("Examination Division") announced its 2024 Examination Priorities. Registrants should ensure that policies, procedures, and...more

SEC’s Focus on Off-Channel Communications Continues

On September 29, the US Securities and Exchange Commission ("SEC") brought its latest wave of enforcement actions related to "off-channel communications," charging 10 additional firms with failing to maintain employee...more

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