Investment Management Regulatory Update - February 2014

SEC Rules and Regulations

• SEC Issues Guidance on Rule 506(c) Exemption
• SEC Issues No-Action Guidance Regarding Definition of “Knowledgeable Employee” Under the Investment Company Act
• IM Guidance Update Urges Risk Management in Changing Fixed Income Market Conditions

Industry Update

• SEC Issues Risk Alert Focusing on Due Diligence Processes of Investment Advisers
• FINRA Loosens Private Fund Anti-Spinning Compliance Regulations for Private Fund Managers and Proposes Rule to Grant Exemptions from Such Regulations Without SEC Approval s

Litigation

• SEC Sanctions Investment Adviser for Defrauding Clients
• SEC Sanctions Investment Adviser for Advisers Act Violations