Securities and Exchange Commission

The U.S. Securities and Exchange Commission recognized that processing delays associated with the unusually large number of Form ID applications being submitted due to the Holding Foreign Insiders Accountable Act may contribute to FPIs failing to meet the March 18, 2026, deadline to comply with such Section 16(a) reporting requirements.

Continue Reading SEC Issues Extension for Compliance with Section 16(a)

On Aug. 21, 2025, Judge Margaret Ryan, a former senior judge of the United States Court of Appeals for the Armed Forces, was named the Securities and Exchange Commission’s director of the Division of Enforcement.
Continue Reading SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement Priorities

On Nov. 17, 2025, the U.S. Securities and Exchange Commission (SEC) issued a No-Action Letter confirming that it will not recommend enforcement action if a registered representative-owned personal services entity

Continue Reading Path Cleared for Registered Representative-Owned PSEs To Receive Transaction-Based Compensation

In 2021, the SEC adopted the Marketing Rule, and in 2023, issued an FAQ requiring private fund managers to show net-of-fees performance alongside gross performance. Managers found it difficult to calculate net performance for individual investments, as fees are generally charged at the fund level.
Continue Reading SEC’s Marketing Rule Updates May Provide Relief for Investment Managers

On March 3, 2025, the Securities and Exchange Commission’s Division of Corporation Finance issued new guidance expanding the availability of confidential (nonpublic) review of draft registration statements (DRS).

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Continue Reading SEC Expands Confidential Review Process for Draft Registration Statements