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SEC Risk Alert Shines Spotlight on Private Funds

USA - September 25 2020 On June 23, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert focused on…

Eliza Sporn Fromberg, Erik A. Bergman, Peter J. Bilfield, Lydia Joo Lee

Key Corporate Governance Points for the Board of a Privately Held Company Relating to the COVID-19 Pandemic

USA - April 6 2020 The following is a summary of key corporate governance points that the Board of Directors (or the manager or the board of managers of a limited…

Michael J. Dunne, Brian W. Fischer

Dating advice for Internet platforms: SEC provides guidance on how to form substantive pre-existing relationship

USA - August 13 2015 Can you form a substantive, pre-existing relationship in fewer than 30 days? For Internet platforms offering private placements in reliance on Rule…

Eliza Sporn Fromberg, Jeffrey A. Clopeck

"Custody Rule" information delays lead to enforcement against investment adviser

USA - November 4 2014 Securities and Exchange Commission (SEC) enforcement actions have moved out of the realm of punishing wrongdoers for harm caused and into preemptive…

Jennifer Genovesi Bassett

SEC makes fundamental changes to private capital-raising rules

USA - July 15 2013 On July 10, the Securities and Exchange Commission ("SEC" or the "Commission") approved final rules eliminating the decades-old prohibition against…

Eliza Sporn Fromberg, R. Scott Beach, Greg H. Kahn, Michael T. Rave