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SEC Sends Additional Message to Registered Investment Advisers on Marketing Rule Obligations Through Enforcement Actions

On September 9, 2024, approximately one year since its first flurry of similar Marketing Rule actions, the Securities and Exchange Commission (the SEC) announced settlements with nine SEC-registered investment advisers (the...more

The SEC Amends the Internet Adviser Exemption

On March 27, 2024, the US Securities and Exchange Commission (SEC) adopted amendments to Rule 203A-2(e) of the Investment Advisers Act of 1940 (the Advisers Act) (the Internet Adviser Exemption)....more

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

On September 5, 2023, almost one year since its first flurry of similar Custody Rule actions,  the SEC announced settlements with five SEC-registered investment advisers to private funds with respect to alleged violations of...more

SEC Announces Focus Areas for Next Stage of Marketing Rule Exams

On June 8, 2023, the Division of Examinations (EXAMS) of the Securities and Exchange Commission (the SEC) published a Risk Alert regarding its priorities for the next stage of examinations with respect to Rule 206(4)-1 (the...more

SEC Proposes Radical Transformation of Custody Rule Into New Safeguarding Rule

On February 15, 2023, the Securities and Exchange Commission (the “SEC”) proposed a significant transformation of Rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) into a new...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

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