Updated Marketing Rule FAQ Relieves Fund Managers From Calculating Investment-Level Net Returns
On March 19, 2025, staff from the Securities and Exchange Commission (SEC staff) updated its prior guidance regarding the requirement to show net returns of an individual investment, or subset of investments, in compliance with Rule 206(4)-1 (Marketing Rule) under the Investment Advisers Act of 1940.
SEC Staff Takes Steps to Allow Funds to More Comfortably Fundraise Under Rule 506(c)
On March 12, 2025, staff from the Securities and Exchange Commission (SEC staff) issued new guidance regarding Rule 506(c) of Regulation D under the Securities Act of 1933 (Securities Act). We expect that such guidance will improve the compliance experience that fund sponsors encounter should they seek to rely upon […]
Q4 2024 Venture Financing Report – Interview With Alexa von Tobel
In conjunction with our Q4 2024 Venture Financing Report, we sat down with Alexa von Tobel of Inspired Capital to get her take on the state of venture capital investing. Key insights from Alexa von Tobel On investing in companies driving industry disruption: “We believe that venture capital – when properly deployed – […]
Annual SEC Section 13 Filing Requirements for Venture, Private Equity Funds
Venture and private equity funds and other investors that own equity securities of public companies may have numerous Securities and Exchange Commission (SEC) filing requirements – including filings based on the size of the holdings of a particular portfolio company, aggregate holdings of securities across all public portfolio companies, and […]
Q3 2024 Venture Financing Report – Interview With Asad Khaliq
In conjunction with our Q3 2024 Venture Financing Report, we sat down with Asad Khaliq of Acrew Capital to get his take on the state of venture capital investing. Key insights from Asad Khaliq On the most exciting advancements in technology right now: “Cybersecurity is unique in that progress is […]
Navigating the SEC’s New XML Filing Requirements for Schedules 13D and 13G: What Funds Need to Know
On December 18, 2024, new requirements go into effect that mandate the use of the XML format for Schedules 13D and 13G filings with the US Securities and Exchange Commission (SEC). The XML reporting requirements represent the final change required by the SEC’s wide-ranging amendments to its beneficial ownership reporting […]
Are You a Fund Manager Looking to Set Up a Separate Entity and Avoid Registration? Recent SEC Enforcement Action Highlights Risks of Operational Integration for Firms
In a recent enforcement action announced by the Securities and Exchange Commission (SEC), the issue of how one investment adviser can affect the exemption status of related advisers under the Investment Advisers Act of 1940 (Advisers Act) has come into focus. The action serves as a timely reminder for fund […]
Amended Filing Deadlines for Schedule 13G Filers Go Into Effect September 30, 2024
In 2023, the Securities and Exchange Commission (SEC) adopted wide-ranging rule changes applicable to beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act. These rule changes are described in this October 30, 2023 Cooley alert. While certain of the rule changes became effective in February 2024, […]