Given the continued and growing interest in special purpose vehicles (“SPVs”) as a means of accessing private market investments, we are publishing a series of posts that examine different aspects of these structures. This is our third post in the
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SEC Staff Issues No-Action Relief for “Zero Cash Balance” Brokerage Account Models
On September 17, 2026, the Staff of the Division of Trading and Markets (the “Division”) of the Securities and Exchange Commission (the “SEC”) issued two no-action letters addressing the net capital and customer protection implications of “zero cash balance” brokerage
Proposed Expansions to the Accredited Investor Definition for Natural Persons
Earlier this week, the Securities and Exchange Commission continued to implement its capital-formation agenda by publishing a number of notices aimed at modernizing the definition of “accredited investor,” including introducing the possibility of a long-discussed accredited investor exam.
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SEC Proposes Expansion of Accredited Investor Definition
On September 30, the Securities and Exchange Commission (the “Commission” or the “SEC”) published a number of notices aimed at modernizing the definition of “accredited investor,” including the possibility of a long-discussed accredited investor exam.
In their proposals, the Commission
SEC Proposes Amendments That Address Retailization and Modernize Regulated Funds
On September 30, 2026, the Securities and Exchange Commission (the “SEC”) proposed amendments intended to provide additional flexibility for regulated funds and their investment advisers. The proposals address performance-based compensation, interval fund repurchase requirements and multiple share classes for registered
SEC Staff Highlights Fair Value and Disclosure Considerations for Private Assets
The staff of the Securities and Exchange Commission, including the Office of the Chief Accountant and the Division of Investment Management (the “Staff”), recently issued a Statement on Fair Value Measurement and Disclosure Considerations for Private Assets (the “Statement”). The
SEC Division of Corporation Finance Issues FAQs on the Application of Federal Securities Laws to Crypto Assets
On September 25, 2026, the Staff of the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC”) published a set of responses to frequently asked questions (the “FAQs”) regarding the application of the federal securities
BDC Facts & Stats 2026
Revamping Abbreviated Disclosure Requirements for Equity-Linked Securities 30 Years Following Issuance of the Morgan Stanley No-Action Letter
This week, the Staff of the Division of Corporation Finance of the Securities and Exchange Commission granted our no-action letter modernizing and expanding the framework established with the issuance of the 1996 Morgan Stanley no-action letter (“MS Letter”). This no-action
Division of Corporation Finance Updates and Withdraws Dated CFIs
On September 26, the Securities and Exchange Commission’s Division of Corporation Finance continued its ongoing efforts to update and revise the Staff guidance in the form of Corporation Finance Interpretations, or CFIs. The updates address various topics, ranging from Securities