…13D amendments be filed within two business days (rather than “promptly,” which had been interpreted by many practitioners as within one business day in most cases involving ownership changes under…
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SEC Proposes ESG Rule
The Securities and Exchange Commission has proposed to amend rules and forms under both the Investment Advisers Act of 1940 and the Investment Company Act of 1940 to require…
SEC Adopts Rules to Require Electronic Filing for Investment Advisers and Institutional Investment Managers
In today’s press release, the Securities and Exchange Commission announced the adoption of rules and amendments to require certain documents, including Form ADV-NR, filed by investment advisers, institutional investment…
SEC Division of Examinations Announces 2022 Examination Priorities
manage private funds. Examinations will review issues under the Advisers Act, including an adviser’s fiduciary duty, and will assess risks, including a focus on compliance programs, fees and expenses, custody,…
SEC Proposed Rules to update beneficial ownership reporting
The SEC today proposed rule amendments to update beneficial ownership reporting under 1934 Act Sections 13(d) and 13(g). The proposed amendments to Regulation 13D-G would: accelerate the…
SEC Proposes Amendments to Enhance Private Fund Reporting
The Securities and Exchange Commission today voted to propose amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds. The proposed amendments are…
Gensler SEC Expands Scope of Insider Trading Enforcement
…Panuwat enforcement action advances the novel theory that possessing confidential information about one issuer may preclude trading in the securities of competitors and other companies in a business sector. In…
Dollar Threshold Change for “Qualified Client” Definition under the Investment Advisers Act
…hedge fund managers will have to comply with the qualified client standard in their 3(c)(1) funds under certain state laws. _________________________________________________ Please contact your attorney at Pillsbury’s Investment Funds Group…
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SEC Adopts Modernized Marketing Rule for Investment Advisers
Today, the Securities and Exchange Commission announced it had finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors. The…