Laure Sguario

3 weeks ago | jdsupra.com | Jeff VonDruska |Adam Goldman |Joseph Mannon |Laure Sguario

On March 12, 2025, the staff of the Securities and Exchange Commission (“SEC”) issued no-action guidance providing that certain minimum investment amounts, along with certain written representations from the purchaser, could constitute “reasonable steps” to verify a purchaser’s accredited investor status in an offering conducted under Rule 506(c) of Regulation D.

3 weeks ago | jdsupra.com | Adam Goldman |Joseph Mannon |Laure Sguario

On March 19, 2025, the Securities and Exchange Commission (“SEC”) updated its frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”).[1] The new FAQs permit the use of certain performance-related metrics (e.g., yield, coupon rate, contribution to return, volatility, sector or geographic returns, attribution analyses, the Sharpe ratio, the Sortino ratio, and other similar metrics) and extracted performance on a gross basis...