SEC Release No. IA-6961 (issued April 28, 2026, attached) adjusts the “qualified client” dollar thresholds under Rule 205-3 of the Investment Advisers Act of 1940 for inflation. Effective June 29, 2026, the new thresholds increase to $1,400,000 for assets-under-management and
Investment Fund Law Blog
The Investment Fund Law Blog, published by Pillsbury Winthrop Shaw Pittman LLP, focuses on legal developments affecting investment funds and their management. It covers regulatory updates from the SEC, including amendments to beneficial ownership reporting, insider trading enforcement, and ESG-related rules. The blog also addresses compliance issues, private fund regulations, and changes in definitions relevant to investment advisers and clients. It provides analysis of securities laws impacting private equity, hedge funds, and other investment vehicles, as well as guidance on navigating evolving financial regulatory frameworks.
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SEC Adopts 13D/13G Amendments
The SEC adopted today amendments that will, among other things:
- shorten the deadline for initial Schedule 13D filings from 10 days to five business days;
- require that Schedule 13D amendments be filed within two business days (rather than “promptly,” which
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SEC Proposes ESG Rule
The Securities and Exchange Commission has proposed to amend rules and forms under both the Investment Advisers Act of 1940 and the Investment Company Act of 1940 to require registered investment advisers, certain advisers that are exempt from registration, registered…
SEC Proposed Rules to update beneficial ownership reporting
The SEC today proposed rule amendments to update beneficial ownership reporting under 1934 Act Sections 13(d) and 13(g).
The proposed amendments to Regulation 13D-G would:
- accelerate the filing deadlines for Schedule 13D beneficial ownership reports from 10 days to five
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Gensler SEC Expands Scope of Insider Trading Enforcement
Recent enforcement action could signal expanding the boundaries of misappropriation theory, with significant implications for SEC-regulated entities and other market participants.
TAKEAWAYS
- With Chair Gensler at the helm, an emboldened SEC Enforcement Division will continue to take aggressive positions in
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Dollar Threshold Change for “Qualified Client” Definition under the Investment Advisers Act
Most 3(c)(1) private equity and hedge funds are impacted; exempt venture capital funds are not impacted.
Effective August 16, 2021, the dollar thresholds specified in the definition of “qualified client” under Rule 205-3 of the Investment Advisers Act of 1940,…
SEC Adopts Modernized Marketing Rule for Investment Advisers
Today, the Securities and Exchange Commission announced it had finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors. The amendments create a single rule that replaces the current advertising and…
Commodity Pool Operators: Final Rule Amending Form CPO-PQR
The Commodity Futures Trading Commission at its open meeting on Tuesday, October 6, unanimously approved a final rule adopting amendments to Form CPO-PQR for commodity pool operators (CPOs).
The amendments to Form CPO-PQR (1) eliminate existing Schedules B and C…