Regulatory Framework and Oversight
Generally, managers who act as advisers to registered funds and private funds in private corporate credit are registered investment advisers (RIAs).
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The SEC’s Brightline on MNPI Policies and Procedures
Two recent settlements demonstrate the SEC’s focus on whether RIAs have established, maintained and enforced policies and procedures regarding the use of MNPI.
New Customer Identification Program Requirements for Investment Advisers
Registered Investment Advisers (“RIAs”) are facing a new compliance environment under two related proposals targeting money laundering and suspicious financial activity. Last month, the U.S.…
The SEC’s Oversight Rule for Advisers: A Deeper Dive and Many Concerns
We have previously summarized the SEC’s recent proposed rule on Outsourcing by Investment Advisers (the “Proposed Rule”) that would require Registered Investment Advisers (advisers) to conduct…
The SEC Targets Outsourcing by RIAs
While we have been focusing on the SEC’s latest liquidity management proposal (which, among other things, poses an existential threat to loan funds), in late…
CLOs/Arrangers Grapple with the SEC’s New Adviser Marketing Rule
On November 4th, a revised Marketing Rule promulgated by the SEC goes into effect. The Rule (which was described in detail in an LSTA webinar…
COVID-19 Disruption: What Registered Investment Advisers in the Loan Market Need to Know Webcast Replay
In the wake of the COVID-19 Pandemic, the SEC has taken emergency steps to address disruption for registered advisers but will also be focusing on…
Registered Investment Advisers in the Loan Market: Dealing with COVID-19 Disruption
Like virtually all financial markets, the syndicated loan market has been materially disrupted by the COVID-19 pandemic.
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