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SEC Staff Updates FAQs Regarding Marketing Rule Compliance – Gross and Net Performance

On March 19, 2025, the staff of the Division of Investment Management (the “SEC Staff”) of the Securities and Exchange Commission (the “SEC”) released an update to its Frequently Asked Questions1 (the “FAQs”) relating to...more

New Restrictions on Investments into Chinese Entities: Considerations for Advisers, Private Funds, and Investors

U.S. law has long subjected foreign investments into the U.S. to review and restriction by the Committee on Foreign Investment in the United States (“CFIUS”), but outside of economic sanctions programs, has typically not...more

Client Reminder: Required Gross Short Position and Activity Reporting by Institutional Investment Managers on Form SHO

Seward & Kissel is reminding its clients about the recent January 2, 2025 compliance date for new Rule 13f-2 (the “New Rule”) under the Securities Exchange Act of 1934 (the “Exchange Act”), as well as related reporting on...more

Private Equity Investment into NFL Teams: Tax and Business Considerations

Owning an NFL team is no longer a fantasy. The National Football League (the “NFL” or the “League”) voted to allow minority stakes to be sold to private equity firms (“PE”). However, according to NFL.com, “an executive from...more

SEC Charges FinTech Investment Adviser with First Violation of the Marketing Rule and Additional Compliance Violations

Recently, the U.S. Securities and Exchange Commission (the “SEC”) announced charges against an investment adviser (the “Adviser”) for using hypothetical performance metrics in advertisements that were misleading pursuant to...more

New Marketing Rule: One Month Away from the Compliance Date

On December 20, 2020, the Securities and Exchange Commission (the “SEC”) adopted reforms under the Investment Advisers Act of 1940, which modernized rules that govern investment adviser advertising and payments to solicitors....more

Private Equity Side Letters Post-ILPA 3.0

In June 2019, the Institutional Limited Partners Association (“ILPA”) released the third edition of its private equity industry best practices principles fostering transparency, governance and alignment of interests for...more

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