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Fifth Circuit Vacates SEC Private Fund Adviser Rules in Full

In a unanimous decision published on June 5, 2024, the US Court of Appeals for the Fifth Circuit vacated the entire set of regulations, including amendments to existing rules (collectively, the Rules), adopted by the US...more

SEC Adopts New Private Fund Adviser Rules with Nuanced Application to Non-US Advisers

The US Securities and Exchange Commission (SEC) recently adopted sweeping new rules under the Investment Advisers Act of 1940 (Advisers Act) that apply in certain circumstances to non-US advisers to private investment funds....more

New Executive Order Carries Forward, Expands Chinese Military Company Sanctions

The new executive order continues the policy of prohibiting US persons’ transactions in the publicly traded securities of select Chinese companies, but expands the scope to include both Chinese companies that operate or have...more

Deadline for Filing BE-180 Approaches for US Financial Service Providers

As the US Department of Commerce seeks certain financial services data from an expanded list of US financial services providers, most US fund managers, investment advisers, private funds, and registered investment companies...more

BE-180 Deadline Approaching: Fund Managers, Private Funds, and Registered Investment Companies May Be Required to File

The November 1, 2015 deadline is approaching for US financial services providers—including many US fund managers, private funds, and registered investment companies—to file a BE-180 with the US Department of Commerce....more

BEA Indicates That It Will Grant Extensions for Filing Be-10 Until August 31, 2015

Filers seeking an extension must submit a Request for Extension. On May 29, we issued a LawFlash reporting that the US Department of Commerce’s Bureau of Economic Analysis (BEA) extended the BE-10 reporting deadline for...more

Deadline for Filing BE-10 Has Been Extended for New Filers

The new deadline is June 30. On May 19, we issued a LawFlash regarding the BE-10 reporting requirements for private funds and private fund managers....more

Deadline for Filing BE-10 Approaches for Private Funds and Private Fund Managers

Most private funds or their managers will be required to file a BE-10 with the US Department of Commerce by May 29th. This year marks the return of the BE-10, the five-year benchmark survey of US direct investment...more

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