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Aug 29, 2023 | 
lexology.com | Robert Sutton |Robert Plaze |Mark S. Audet
On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”) adopted its highly anticipated new rules and amendments to existing rules under the Investment Advisers Act of 1940 (“Advisers Act”) impacting private fund advisers (“Private Fund Adviser Rules” or the “Rules”).[1] In a welcome development, the SEC confirmed in its Adopting Release that in most cases the Rules would not apply to advisers located outside of the U.S. (“offshore advisers”), but also clarified that certain...
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Aug 24, 2023 | 
jdsupra.com | Mark S. Audet |Robert Plaze |Robert Sutton
Yesterday, the five SEC commissioners voted 3-2, along party lines, to approve the Private Fund Adviser Rules. The final Rules scale back from what was initially proposed 18 months ago, in ways that are likely to be a relief to many private fund advisers.
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Aug 24, 2023 | 
lexblog.com | Robert Sutton |Robert Plaze |Mark S. Audet
Robert is a partner of the Private Funds Group and a member of the Corporate Department. He is a seasoned practitioner with over 20 years of experience counseling managers and advisers of private funds on regulatory matters, as well as regulatory issues related to the formation and operation of private equity, credit, real estate, infrastructure, hedge and other private funds.
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Aug 24, 2023 | 
privateequitylitigation.com | Robert Sutton |Robert Plaze |Mark S. Audet
Yesterday, the five SEC commissioners voted 3-2, along party lines, to approve the Private Fund Adviser Rules. The final Rules scale back from what was initially proposed 18 months ago, in ways that are likely to be a relief to many private fund advisers.
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Apr 5, 2023 | 
natlawreview.com | Mark S. Audet
On March 15, 2023 the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information, while simultaneously issuing two additional cybersecurity-related rule proposals[1] and re-opening the comment period for its previously-proposed cybersecurity risk management rule released in February 2022.[2] This set of sweeping reforms makes it clear, if not already, that the SEC is serious...
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Apr 5, 2023 | 
jdsupra.com | Mark S. Audet |Ryan Blaney |Nolan Goldberg
On March 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Proposed Amendments”), while simultaneously issuing two additional cybersecurity-related rule proposals[1] and re-opening the comment period for its previously proposed cybersecurity risk management rule released in February 2022.[2] This set of sweeping reforms makes it clear, if not...
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Apr 5, 2023 | 
lexblog.com | Mark S. Audet |Ryan Blaney |Nolan Goldberg |Robert Plaze
CybersecurityNolan’s electrical engineering background, coupled with a litigation and risk management-centric focus, allows him to assist companies in all phases of incident response. Nolan often acts as a bridge between the technical and legal response teams (both inside and outside forensic consultants).
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Apr 4, 2023 | 
lexology.com | Ryan Blaney |Nolan Goldberg |Robert Plaze |Robert Pommer |Robert Sutton |Mark S. Audet
On March 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Proposed Amendments”), while simultaneously issuing two additional cybersecurity-related rule proposals[1] and re-opening the comment period for its previously proposed cybersecurity risk management rule released in February 2022.[2] This set of sweeping reforms makes it clear, if not...
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Feb 16, 2023 | 
jdsupra.com | Mark S. Audet |Robert Plaze |Robert Sutton
On February 7, 2023, the Division of Examinations (“Division” or EXAMS”) of the U.S. Securities and Exchange Commission (“SEC”) released its 2023 Examination Priorities (“Annual Priorities”). Released at the beginning of each calendar year, the priorities tend to repeat the previous year’s priorities, and consumers of these regulatory tea leaves need to search closely for clues as to what is new and meaningful.
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Feb 15, 2023 | 
lexblog.com | Robert Plaze |Robert Sutton |Mark S. Audet
On February 7, 2023, the Division of Examinations of the U.S. Securities and Exchange Commission released its 2023 Examination Priorities (“Annual Priorities”). Released at the beginning of each calendar year, the priorities tend to repeat the previous year’s priorities, and consumers of these regulatory tea leaves need to search closely for clues as to what is new and meaningful.
