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SEC Adopts New Rules for Private Fund Advisers

On August 23, 2023, the Securities Exchange Commission (the “SEC”) adopted significant new rules for private fund advisers (the “Rules”)…

SEC Enforcement Actions for Custody Rule Violations

On September 5, 2023, the Securities Exchange Commission (the “SEC”) charged five advisory firms with violations of Rule 206(4)-2 (the…

SEC Adopts Amendments to Expand the Scope of Form PF

On May 3, 2023, the Securities Exchange Commission (the “SEC”) approved significant amendments to Form PF (the “Amendments”), the confidential…

Join Us at SohnSF – September 26

Shartsis Friese LLP has joined other prominent firms in the San Francisco Bay Area investment funds community to sponsor the…

Upcoming July 1, 2023, Compliance Deadline under the California Consumer Privacy Act

Generally, an adviser that does business in California and has a gross annual revenue of over $25 million in the…

Exempt Reporting Advisers and State Registered Advisers – FTC Safeguards Rule – June 9 Compliance Deadline

As noted in our Annual Letter, in 2021 the Federal Trade Commission adopted expanded and detailed rules implementing the requirement…

Insider Trading – 2022 In Review

With the start of a new year, it’s a good time to look back at 2022’s developments in insider trading….

Annual Letter: 2023

This is our annual letter briefly reviewing various issues that our investment adviser clients should consider over the next few…

Recent SEC Enforcement Actions Indicate Strict Regulatory Interpretations

Two recent enforcement “sweeps” by the U.S. Securities and Exchange Commission (“SEC”) serve as a reminder that the SEC at…

Upcoming Compliance Deadline for SEC Marketing Rule Compliance

The November 4, 2022 deadline for compliance with Rule 204(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940…

Proposed Inflation Reduction Act of 2022

The recently proposed Inflation Reduction Act of 2022 (“IRA”) includes a number of tax provisions, the most important of which…

SEC Proposes Fundamental Changes to Private Fund Regulation

The U.S. Securities and Exchange Commission (the “SEC”) recently proposed extensive new rules and amendments under the Investment Advisers Act…

“Shadow Trading” – District Court Upholds the SEC’s Shadow Insider Trading Theory

Back in August 2021 the Securities and Exchange Commission filed a first-of-its-kind “shadow” insider trading case against Matthew Panuwat. Mr….

Annual Letter: 2022

This is our annual letter briefly reviewing various issues that our investment adviser clients should consider over the next few…

THE SEC BRINGS AN “ALT DATA” ENFORCEMENT CASE

On September 14, 2021, the SEC brought an unusual enforcement action against App Annie, a so-called “alt data” provider, and…

SEC INSIDER TRADING CASE IS NOVEL, BUT NOT AN EXPANSION OF THE LAW

Last month the SEC filed a novel insider trading case worth taking a look at (a link to the SEC…

Client Alert: Gov. Newsom Signs A.B. 150 – SALT Workaround

Gov. Gavin Newsom signed A.B. 150 into law on July 15, 2021. This law creates a workaround to the $10,000…

SEC Raises “Qualified Client” Net Worth Threshold Effective August 16, 2021

The U.S. Securities and Exchange Commission (the “SEC”) recently announced in Advisers Act Release 5756 that it has adjusted for…

SPAC PIPES AND MNPI COMPLIANCE (or, acronyms run amok)

The majority of insider trading compliance questions this year, by a wide margin, have been related to SPAC PIPE offerings. …

New SEC Marketing Rule for Investment Advisers

The Securities and Exchange Commission (the “SEC”) has finalized significant revisions to its rules under the Investment Advisers Act governing…

Annual Letter: 2021

This is our annual letter briefly reviewing various issues that our investment adviser clients should consider over the next few…

Upcoming SEC Seminar for Investment Advisory CCOs and Other Senior Personnel

The Securities Exchange Commission (the “SEC”) has rescheduled its compliance outreach program’s national seminar for investment companies and investment advisers…

Form BE-180, 2019 Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons

In September and October, the U.S. Bureau of Economic Analysis (“BEA”) is conducting its 2019 Benchmark Survey of Financial Services…

New SEC Accredited Investor Categories and Rule 144A Amendments

The “accredited investor” definition largely has been unchanged since 1982, but on August 26, 2020, the Securities and Exchange Commission…

SEC Investment Adviser Enforcement Actions: “May” Might Be Materially Misleading & Insider Trading Policies

Two topics from recent SEC investment adviser enforcement cases, disclosure language and insider trading policies. Adviser Disclosures: What does “may”…