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SEC pay-to-play Placement Agent Restriction delayed, and a reminder for campaign season

USA - July 9 2015 On June 25, 2015, the staff of the Securities and Exchange Commission (the "SEC") again delayed the compliance date of the provision of Rule 206(4)-5...

Julie Baine Stem, Michael P. Harrell, Jennifer R. Cowan, Jordan C. Murray.


SEC staff provides no-action relief from Custody Rule for Principals-Only Funds

USA - March 31 2015 On March 23rd, the Division of Investment Management of the Securities and Exchange Commission (the "SEC Staff") issued a no-action letter addressing...

Jonathan Adler, Kenneth J. Berman, Gregory T. Larkin, Rebecca F. Silberstein, Jordan C. Murray.


Treatment of SPVs and M&A escrow accounts under the Advisers Act Custody Rule

USA - July 11 2014 The treatment of special purposes vehicles ("SPVs") used to facilitate investments in portfolio companies has presented issues under Rule 206(4)-2...

Kevin M. Schmidt, Kenneth J. Berman, Michael P. Harrell, Gregory T. Larkin, Andrew M. Ostrognai.


SEC issues guidance with respect to proxy advisory firms and proxy voting by investment advisers

USA - July 3 2014 On June 30, 2014, the SEC issued Staff Legal Bulletin No. 20 from the Division of Investment Management and the Division of Corporation Finance...

Kenneth J. Berman, Gregory T. Larkin, Alan H. Paley, Anne C. Meyer.


The SEC’s examination priorities for 2014

USA - January 28 2014 The SEC's Office of Compliance Inspections and Examinations ("OCIE") recently published the priorities of its National Exam Program ("NEP") for 2014...

Kenneth J. Berman, Michael P. Harrell, Matthew E. Kaplan, Jonathan R. Tuttle, John V. Ponyicsanyi.