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Judge Dismisses Case Against Seeking Alpha: Implications for Publishers of Financial Information

In a recent decision, the US District Court for the Southern District of New York dismissed a proposed class action against Seeking Alpha, Inc., ruling that the financial content platform falls within the "publisher's...more

Client Alert: Proposed SEC Rules for Investment Advisers and Regulated Funds, and New FTC Safeguard Rule Applicable to Private...

On February 9, 2022, the Securities and Exchange Commission (SEC) voted to propose new rule 206(4)-9 under the Investment Advisers Act of 1940 (Advisers Act) and 38a-2 under the Investment Company Act of 1940 (collectively...more

SEC Increases Registered Investment Adviser Performance Compensation Net-Worth and Assets-Under-Management Tests

Key Points - Effective as of August 16, the dollar amount tests specified in the definition of “Qualified Client” in Rule 205-3 under the Investment Advisers Act of 1940 (Advisers Act) will increase for the net-worth...more

SEC Proposes Principles-Based Changes to Investment Adviser Advertising and Solicitation Rules, Seeks Industry Reaction by...

Key Points - SEC proposes significant changes to the Advisers Act “Advertising Rule” and “Cash Solicitation” Rule. - The proposed definition of “Advertisements” expands the types of communications that are considered...more

DC Circuit Decision Against Investment Adviser Leaves Many Unanswered Questions

On April 30, 2019, US Court of Appeals for the DC Circuit decided an important case involving the disclosure obligations of investment advisers. The case decided that an adviser’s disclosure that it “may” have a conflict of...more

SEC Proposes Conduct Standards for Investment Advisers

On April 18, concurrently with its publication for comment of a proposed fiduciary rule for brokers,1 the Securities and Exchange Commission (SEC) took several actions that broadly implicate investment advisers....more

SEC Issues Update for Advisers Relying on the Unibanco No-Action Letters

Recently, the staff (Staff) of the US Securities and Exchange Commission's (SEC) Division of Investment Management issued an information update (the "Information Update") for investment advisers registered under the...more

SEC Proposes Rule Requiring Investment Advisers To Adopt Business Continuity and Transition Plans

On June 28, the Securities and Exchange Commission (SEC) proposed a new rule, Rule 206(4)-4 (the "Proposed Rule") under the Investment Advisers Act of 1940 (the "Advisers Act"), that would make it unlawful for an...more

SEC Enforcement Action Signifies the Need for Investment Advisers to Adopt Written Expense Allocation Policies

On June 29, the Securities and Exchange Commission charged Kohlberg Kravis Roberts & Co. (KKR) with violations of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940, as amended, and Rule 206(4)-7 thereunder for...more

SEC Division of Investment Management Issues Guidance Update Relating to Rule 204A-1 of the Investment Advisers Act

In June, the Securities and Exchange Commission’s Division of Investment Management issued a Guidance Update relating to Rule 204A-1 under the Investment Advisers Act of 1940. Rule 204A-1 provides that a registered investment...more

Effective Date of Investment Adviser Pay-to-Play Rule Ban on Third-Party Solicitation

The Securities and Exchange Commission’s Rule 206(4)-5 (Pay-to-Play Rule) under the Investment Advisers Act of 1940, as amended, prohibits, among other restrictions, an investment adviser subject to the rule, and its covered...more

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