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FinCEN (and SEC) Propose New Customer Identification Program Rule With Minimal Expected Impact on Private Fund Sponsors

On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more

Our Comments on the SEC’s Proposed Safeguarding Rule

On February 16, 2023, we circulated a client alert, “SEC Proposes Radical Transformation of Custody Rule Into New Safeguarding Rule,” concerning the proposed significant transformation of Rule 206(4)-2 (the Custody Rule)...more

SEC Cybersecurity Rules Target Investment Advisers and Investment Companies

On February 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed a package of new rules and amendments to enhance cybersecurity preparedness and improve cyber resilience of investment advisers and investment...more

SEC Proposes Radical Changes to Private Fund Regulation

On February 9, 2022, the U.S. Securities and Exchange Commission (the “SEC”) proposed a package of new rules and amendments that will significantly affect all private fund advisers, including those that are not registered...more

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