On August 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements regarding “off-channel communications.”1 As part of its Off-Channel Communications Initiative,2 the SEC settled...more
On August 21, 2024, the U.S. Securities and Exchange Commission (SEC) adopted a rule (Final Rule) that will increase the threshold for what is considered a “qualifying venture capital fund” from $10,000,000 to $12,000,000....more
On August 26, 2024, the Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (RIA) for failing to establish, maintain and enforce adequate written policies and procedures...more
On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for...more
9/5/2024
/ Campaign Contributions ,
Closed-End Funds ,
Federal Elections ,
Government Entities ,
Government Officials ,
Investment Adviser ,
Pay-To-Play ,
Policies and Procedures ,
Political Contributions ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On May 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (Adviser) that found the Adviser had (a) failed to adequately disclose conflicts pertaining to...more
On April 15, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser), whereby the Adviser paid a $60,0000 civil money penalty of in addition to being censured for...more
On April 5, 2024, a jury found Matthew Panuwat civilly liable for insider trading in violation of federal securities laws in a first-of-its-kind “shadow trading” case (also referred to as “sympathy trading”), which was...more
On April 3, 2024, the U.S. Securities and Exchange Commission (SEC) announced yet another settlement regarding “off-channel communications.” As we have previously written about, settlements of this type have become...more
Limited partnership agreements and similar documents that govern private funds are often amended over the course of a fund’s life cycle. For example, many funds may be currently going through the amendment process in...more
On February 14, 2024, the U.S. Securities and Exchange Commission (the SEC) proposed a rule (the Proposal) that would increase the threshold for what is considered a “qualifying venture capital fund” from $10 million to $12...more
On December 26, 2023, the U.S. Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser, OEP Capital Advisors, L.P. (OEP). The settlement found that OEP had failed (a) to maintain...more
On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) adopted new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act), to address certain conflicts of interest and...more
10/25/2023
/ Fund Managers ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investors ,
Legacy Funds ,
Policies and Procedures ,
Pooled Investment Vehicles ,
Preferred Treatment ,
Private Funds ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Transparency
On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) announced the enactment of a series of new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act). We refer to these...more
8/30/2023
/ Audits ,
Compliance ,
Consent ,
Custody Rule ,
Disclosure Requirements ,
Final Rules ,
Fund Managers ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
Private Funds ,
Quarterly Report ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Transparency
As we previously wrote, the Securities and Exchange Commission (the “SEC”) proposed several rules that would impose additional requirements on private fund managers (“Managers”), many of which relate to various types of...more