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SEC Division of Investment Management and Office of Compliance Inspections and Examinations Respond to COVID-19

USA - May 4 2020 The U.S. Securities and Exchange Commission (SEC) Division of Investment Management has provided guidance to investment advisers on numerous topics…

Halima A. Nguyen, Michael G. Wu

Private Fund Advisers Have Additional Time to Distribute Audited Financial Statements Under SEC Custody Rule

USA - April 30 2020 Advisers to private funds that rely on the audited pool exception to avoid a surprise audit have been provided additional time to meet the delivery…

Halima A. Nguyen, Michael G. Wu

Registered Investment Advisers and Broker-Dealers Must Comply with Form CRS/Regulation BI by June 30, 2020

USA - April 23 2020 The June 30, 2020 compliance date for Regulation Best Interest (Reg BI) and Form CRS will not be extended, U.S. Securities and Exchange Commission…

Halima A. Nguyen

SEC Proposes Amendments to the Investment Advisers Act Rules on Advertising and Cash Solicitation

USA - November 14 2019 On November 4th, the Securities and Exchange Commission (“SEC”) announced proposed amendments, which can be found here, intended to modernize the…

Joseph H. Nesler, Halima A. Nguyen, Michael G. Wu

Custody Rule Traps for the Unwary

USA - May 31 2019 In February 2017, the staff of the SEC’s Division of Investment Management (“IM”) released “tri-part” guidance regarding SEC-registered investment…

Basil V. Godellas, Beth R. Kramer, Joseph H. Nesler