On July 21, 2025, to much welcome relief by investment advisers, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its postponement of the effective date of its recently issued anti-money laundering rule (IA AML Rule) from January 1, 2026 to January 1, 2028. The IA AML Rule requires certain registered investment
Beyond the Prospectus: Rethinking Securities in Modern Investing
Join us for an afternoon break to chat about hot topics and trends relevant to your business. Our concise and practical discussions will focus on a variety of developments that impact financial service industries, and we’ll offer insights and considerations that will certainly be of interest to
The Securities and Exchange Commission (SEC) is withdrawing a number of notices of proposed rulemaking due to changes in its priorities and the evolving regulatory landscape. While the SEC initially proposed changes in various areas affecting securities and investment practices, it has determined that no final rules will be issued regarding these proposals at this
The U.S. Securities and Exchange Commission (SEC) has announced the appointment of Brian T. Daly as the new Director of the Division of Investment Management, effective July 8, 2025. Daly, a highly regarded figure in the investment management industry, brings decades of experience advising fund managers and sponsors on regulatory compliance and legal matters.
Daly’s
Authors: Mark J. Cipolletti, Brittain Shaw, Ben Sandlin
On May 12, the U.S. Department of Justice (DOJ) issued updated policy memoranda relating to the investigation and prosecution of white collar crimes, including its White-Collar Enforcement Plan, Revised Corporate Enforcement and Voluntary Self-Disclosure Policy, Memorandum on Selection of Monitors in Criminal Division
On April 16, 2025, the Securities and Exchange Commission (SEC) extended the compliance dates for the amendments to Form N-PORT. The SEC previously adopted amendments to Form N-PORT to require more frequent reporting of monthly portfolio holdings and related information, and to amend certain reporting requirements relating to entity identifiers. In the same release, the
On March 12, 2025, the SEC’s Division of Corporation Finance (the “Division”) issued a No Action Letter regarding the verification of accredited investor status for potential investors in a Rule 506(c) offering under Regulation D which may streamline verification requirements in such offerings.
Rule 506(c) under Regulation D broadly permits issuers to solicit and generally
FINRA has requested comments on a proposed rule to simplify and ease members’ duties related to outside activities of associated persons. The rule would merge existing Rules 3270 and 3280, and cover fewer outside activities and transactions. However, the proposed rule keeps the status quo for outside investment adviser (“IA”) activity at an unaffiliated
On March 14, 2025, the Securities and Exchange Commission (SEC) extended the compliance dates for the amendments to Rule 35d-1 (the Names Rule) under the Investment Company Act of 1940 (1940 Act). The Names Rule requires that a registered investment company invest at least 80% of the value of the fund’s net assets, plus the
The United States Securities and Exchange Commission – divided along political lines– sent to the trash heap a 15-year-old policy allowing its Director of Enforcement to approve new investigations as well as the issuance of subpoenas. See Delegation of Authority to Director of the Division of Enforcement, 17 CFR Part 200; Release Nos. 33-11366; 34-102552