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Fifth Circuit Vacates Private Fund Adviser Rules

On Wednesday, the U.S. Court of Appeals for the Fifth Circuit (the “court”) held that the Securities and Exchange Commission (“Commission”) exceeded its statutory authority when it adopted the Private Fund Adviser Rules...more

SEC Adopts Private Fund Reform Rules

On August 23, 2023, in a 3-2 vote, the SEC adopted a rule package (the “Adopted Rules”) that establishes significant new obligations for private fund advisers under the Investment Advisers Act of 1940. While the Adopted...more

SEC Adopts Amendments to Form PF; Establishes Certain “Event Reporting” Requirements for Private Equity Advisers and Large Hedge...

On May 3, 2023, the SEC adopted amendments to Form PF that will establish new event-reporting requirements for “private equity fund advisers” and “large hedge fund advisers”, and will require certain additional annual...more

SEC Investment Adviser Marketing Rule: Compliance Date is Nov. 4, 2022

In late 2020, the SEC adopted1 rule amendments that require SECregistered investment advisers to, by November 4, 2022, switch their compliance regimes from the SEC’s current Advertising and Cash Solicitation Rules (Rules...more

SEC Issues Significant Private Fund Proposal: Standardized Prohibitions and Requirements

On February 9, in a 3-1 vote, the SEC approved a rule proposal (the "Proposed Rule”) that represents a sea-change in the Commission’s approach to private funds, with the Proposed Rule including provisions that would impose on...more

SEC Updates Qualified Client Threshold

On June 17, 2021, the SEC issued an order (the “Order”) to adjust for inflation the dollar amount thresholds that determine when an investor is a “qualified client” under Rule 205-3 of the Investment Advisers Act of 1940, as...more

SEC Opens Private Capital Markets to New Investors by Expanding Accredited Investor Definition

On August 26, 2020, the Securities and Exchange Commission (SEC) adopted an expanded definition of “accredited investor” in Rule 501(a) under the Securities Act of 1933, as amended (Securities Act). Part of an effort “to...more

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