SEC Order Granting Temporary Exemptive Relief from Compliance with Rule 13f-2 and Form SHO

On December 3, 2025 the SEC issued an Order granting temporary exemptive relief from compliance with Rule 13f-2 and Form SHO.  Pursuant to Rule 13f-2 an “institutional investment manager” (which by definition includes investment advisers) is required to file Form SHO with

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Division of Examinations: SEC Fiscal Year 2026 Examination Priorities for Investment Advisers

On November 17, 2025, the Division of Examinations of the United States Securities & Exchange Commission (the “Division”) published the Fiscal Year 2026 Examination Priorities. In addition to investment advisers, the Division has examination responsibility for broker-dealers, investment companies, self-regulatory organizations, clearing agencies,

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FinCEN Announces Postponement and Reopening of the Investment Adviser Anti-Money Laundering Rule

On July 21, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing the investment adviser anti-money laundering obligations – the IA AML Rule.  In the announcement,

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