In the past 2 years, the U.S. Securities and Exchange Commission (“SEC”) (and other regulatory authorities) have been very busy with new rules, proposals, examination, and enforcement under the Investment Advisers Act of 1940 (the “Advisers Act”), and other applicable statutes. This client update summarizes where recent key rulemaking changes are in the process, highlights issues investment advisers, fund managers, and other financial institutions should be thinking about at this time, describes relevant regulatory guidance, recent litigation, enforcement activities, and provides checklists for investment advisers, commodity pool operators and commodity trading advisors.

The checklists appear after the legal developments summaries. For more information regarding any matter covered in this update, please contact one of the attorneys in our Investment Management Group.