Robert Blumenfeld

Client memorandum | March 21, 2025 Authors: Michael Sherman (Washington, DC), Ashley Rodriguez (Washington, DC), Joanna Rosenberg (New York), Brooke Gibson (New York) On March 19, 2025, the staff of the Division of Investment Management (the “staff”) of the Securities and Exchange Commission (the “SEC”) published two new Marketing Compliance Frequently Asked Questions[1] with respect to Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) and...

Client memorandum | March 17, 2025 Authors: Michael Sherman (Washington, DC), Jonathan Adler (New York), Brooke Gibson (New York) On March 12, 2025, the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) produced new Compliance and Disclosure Interpretations[1] and published a no-action letter issued to Latham & Watkins LLP (the “No-Action Letter”)[2] that include guidance regarding what can constitute “reasonable steps to verify” that investors in a private...

Client memorandum | November 7, 2024 Authors: Michael L. Sherman, Michael Gershberg, Nihal Patel, Joanna Rosenberg On October 21, 2024, the Division of Examinations (”EXAMS”) of the Securities and Exchange Commission (“SEC”) published its examination priorities for 2025 (the “2025 Priorities”).[1] EXAMS’ examination priorities are released annually and are designed to preview key areas where EXAMS intends to focus its resources.