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Disclosure Requirements Risk Alert Securities and Exchange Commission (SEC)

Troutman Pepper

SEC Issues Third Marketing Rule Risk Alert for Investment Advisers

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On April 17, the U.S. Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMS) issued its third risk alert on the amended Rule 206(4)-1 (the Marketing Rule) under the Investment Advisers Act of 1940...more

SEC Compliance Consultants, Inc. (SEC³)

Top Tips for Updating Your 2024 Compliance Program

Every year compliance officers face the unenviable job of performing their compliance program's annual review under Advisers Act Rule 206(4)-7). An essential element of that review is updating the firm's compliance policies...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Akin Gump Strauss Hauer & Feld LLP

SEC Releases Risk Alert on EXAMS Process

Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more

Lowenstein Sandler LLP

SEC Issues Additional Guidance on Investment Adviser Examinations and Compliance With the Marketing Rule

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The Securities and Exchange Commission (SEC) routinely prepares Risk Alerts to provide helpful information to federally registered investment advisors (advisers). On June 8, the SEC released a Risk Alert that described...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Risk Alert Describes Examination Areas for Newly Registered Advisers

On March 27, 2023, the Securities and Exchange Commission’s (SEC’s) Division of Examinations issued a Risk Alert setting forth typical focus areas reviewed by the staff during its examinations of newly registered advisers....more

Lowenstein Sandler LLP

SEC Provides Guidance to Newly Registered Investment Advisers

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The Securities and Exchange Commission (the SEC) routinely prepares Division Risk Alerts to provide helpful information to federally registered investment advisers (advisers). On March 27, the SEC released a Division Risk...more

Dorsey & Whitney LLP

SEC Issues Risk Alert on Observations from Examinations of Newly-Registered Advisers

Dorsey & Whitney LLP on

On March 27, 2023, the SEC’s Division of Examinations (the “Division”) issued a Risk Alert on its observations from examinations of newly-registered advisers. The Division focused on whether newly-registered advisers...more

Dechert LLP

SEC Division of Examinations Publishes Risk Alert Providing Observations from Broker-Dealer Examinations Related to Regulation...

Dechert LLP on

The Securities and Exchange Commission’s Division of Examinations (Division) issued a Risk Alert (Risk Alert) on January 30, 2023 highlighting deficiencies its Staff observed during recent Regulation Best Interest...more

Holland & Knight LLP

SEC Knows Best: Exam Highlights Deficiencies in Broker-Dealer Reg BI Compliance

Holland & Knight LLP on

The SEC's Division of Examinations (Exam) published a Risk Alert on Jan. 30, 2023, summarizing alleged deficiencies its staff observed since Exam started conducting broker-dealer examinations to assess compliance with...more

Dechert LLP

SEC Risk Alert Regarding Reg NMS Rule 606 and Payment for Order Flow Disclosure

Dechert LLP on

Perhaps in anticipation of the Securities and Exchange Commission’s four rulemakings on order execution and handlings, the staff of the SEC’s Division of Examinations (Division) released a risk alert (Risk Alert) on November...more

Goodwin

SEC Staff Risk Alert Criticizes Broker-Dealer Reports on Best Execution and Payment for Order Flow

Goodwin on

The SEC Division of Examinations recently published a Risk Alert on quarterly reports required under Exchange Act Rule 606, which are published by broker-dealers to provide customers with insight into factors influencing...more

Dorsey & Whitney LLP

Federal Enforcement Forum: EXAMS - Implementing Reg NMS Rule 606

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Rule 606: EXAMS – the Division of Examinations – published a Risk Alert on November 10, 2022, providing its Observations Related to Regulation NMS Rule 606 Disclosures. That Rule requires broker-dealers to provide enhanced...more

Seward & Kissel LLP

The New Investment Adviser Marketing Rule: Implications for CLO Managers and Arrangers

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On December 20, 2020, the SEC adopted reforms under the Advisers Act which modernized rules that govern investment adviser advertising and payments to solicitors. On September 19, 2022, the SEC Division of Examinations...more

Goodwin

Practical Guide to the Application of the Marketing Rule to Private Fund Placement Agents

Goodwin on

This article focuses on how the new Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) affects the relationships between investment advisers registered with the U.S. Securities...more

Dorsey & Whitney LLP

The New Adviser Marketing Rule: Division of Examinations Alert

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​​​​​​​The Division of Examinations issued a Risk Alert on September 19, 2022 focused on Advisers Act Rule 206(4)-1, the Advertising Rule, adopted on December 22, 2020. The Rule becomes effective on November 4, 2022....more

Goodwin

SEC Proposes Rules to Improve Risk Management in Clearance and Settlement and to Facilitate Additional Central Clearing for the...

Goodwin on

Regulatory Developments - SEC Proposes Rules to Improve Risk Management in Clearance and Settlement and to Facilitate Additional Central Clearing for the U.S. Treasury Market - On September 14, the SEC proposed rule...more

BCLP

The SEC’s Recent Observations from Examinations into Private Fund Advisers

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In the last five years, the SEC observed a 70% increase in the value of private fund assets. More than 5,000 SEC-registered advisers currently manage approximately $18 trillion in private fund assets, according to the Risk...more

Kilpatrick

SEC Risk Alert Highlights Registered Fund Compliance, Board Oversight, and Disclosure Obligations

Kilpatrick on

On October 26, 2021, the SEC’s Division of Examinations (the “Division”) released a risk alert (the “Risk Alert”) detailing observations from a series of examinations by the Division’s staff (“Staff”) that focused on certain...more

Eversheds Sutherland (US) LLP

SEC’s focus on compliance: What boards should know

Rule 38a-1 under the Investment Company Act of 1940 (the 1940 Act) requires funds to review their compliance programs, as well of those of their service providers, including their investment advisers (advisers), annually....more

Goodwin

U.S. Securities and Exchange Commission Division of Examinations Publishes Observations from its Registered Investment Company...

Goodwin on

The staff of the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (the “Division”) recently published a risk alert spotlighting observations from its “RIC Initiatives” — 200+ examinations of mutual...more

Opportune LLP

What Does The Future Hold For ESG Reporting?

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As more ESG-linked funds flood the financial markets, increased scrutiny around ESG reporting will be necessary to enhance transparency....more

Latham & Watkins LLP

President Biden Presents a Roadmap for Mitigating the Climate Crisis

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A new national strategy report aims to combat climate-related risks to the US financial system. On October 14, 2021, the Biden Administration issued “A Roadmap to Build a Climate-Resilient Economy” (the Roadmap), a...more

Eversheds Sutherland (US) LLP

Greenwashing: A survey of recent litigation

As climate change jurisprudence continues to evolve, an offshoot of “greenwashing” claims has generated a series of headline-grabbing lawsuits. The definitions vary but most references to greenwashing include claims...more

Akin Gump Strauss Hauer & Feld LLP

SEC Charges 21 Advisers for Form CRS Failures – Impact on Private Fund Managers

On July 26, 2021, 21 investment advisers entered into settlements with the Securities and Exchange Commission to resolve charges that they failed to timely file and deliver their relationship summaries on Form CRS. Penalties...more

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