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Legacy Status Under the New SEC Investment Adviser Rules

On Aug. 23, the U.S. Securities and Exchange Commission adopted the PFA Rules, rules and rule amendments under the Investment Advisers Act of 1940 that impose new requirements and obligations on private fund advisers. In previous blog posts, we provided a brief summary of the PFA Rules, discussed the new…

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Summary of the SEC’s 2024 Examination Priorities for Registered Investment Advisers

Yesterday, the United States Securities and Exchange Commission (the “SEC” or the “Commission”) Division of Examinations released its examination priorities to inform market participants of the key topics and priorities that the SEC plans to focus on when conducting examinations on SEC-registered investment advisers, investment companies, broker-dealers, transfer agents, municipal…

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Adviser-Led Secondaries and the SEC’s New Private Adviser Rules

On August 23, 2023, the United States Securities and Exchange Commission (the “SEC” or “Commission”) adopted rules and rule amendments (the “PFA Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”)1 that impose new requirements and obligations on investment advisers to private funds. In our prior blog posts…

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