Publications
Private Funds Regulatory Update
August 2019
August 2019
Contents
SEC Releases Final Interpretation of the Standard of Conduct for Investment Advisers
The SEC has, for some time, been reviewing the standard of conduct required of investment advisers and broker-dealers under federal securities laws. Recently, these various initiatives concluded with the publication of four final items of guidance.
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New Fund-of-Funds Rule for Registered Funds Under SEC Consideration
The SEC is currently considering a rulemaking proposal designed to streamline and enhance the regulatory framework for registered funds-of-funds under the Investment Company Act of 1940.
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OCIE Focusing on Safeguarding of Customer Information and Books and Records Retention
OCIE has recently issued three risk alerts relating to the safeguarding of customer information and books and records obligations. In addition, the SEC’s staff has sent inquiries requesting information on advisers’ use of cloud storage providers.
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National Futures Association Adopts Interpretive Notices Regarding Internal Controls and Cybersecurity
Effective April 1, 2019, the NFA adopted two interpretive notices that impose additional obligations regarding formal supervision of key financial functions and expand and clarify past guidance on addressing cybersecurity risks.
