Check out our Flash Reports for the latest SEC- and compliance-related news, trends, and insights.
As we approach the mid-point of 2025, two compliance deadlines stand out for compliance professionals, amended Regulation S-P and FinCEN’s Anti-money laundering/countering the financing of terrorism Rule (the “AML/CFT” Rule).
Read MoreOn January 23, 2025, the U.S. Supreme Court granted the government’s motion to stay the nationwide preliminary injunction issued by a Texas district court in Texas Top Cop Shop, Inc. This would mean that the reporting of Beneficial Ownership Information under the Corporate Transparency Act (CTA) is back on.
On January 8, the SEC’s Division of Investment Management issued new FAQs on the Investment Company Names Rule, which was amended in 2023. These amendments aim to increase shareholder protection by increasing the scope of funds required to adopt a policy to invest at least 80% of its assets based on the investment approach suggested by the fund name, as well as notice and recordkeeping requirements related to these policies.
In a memorandum released by the White House on Monday, President Trump ordered all government agencies to cease all proposals or issuance of any new rules and to withdraw any unpublished rules that have been sent to the Office of the Federal Register but have yet to be published in the Federal Register.
The Securities and Exchange Commission (“SEC”) announced charges against nine investment advisers and three broker-dealers for failures to maintain records of electronic communications by employees, in violation of federal securities laws. The firms paid penalties ranging from $4 million to $12 million, except for one firm that self-reported its violations and paid the reduced penalty of $600,000.
On December 20, 2024, the SEC announced settled charges against Rose Park Advisors, LLC (“Rose Park”), a Boston registered investment adviser, and its managing partner, Matthew Q. Christensen (“Christensen”). The charges stemmed from failing to disclose significant conflicts of interest related to investments made by one of their clients (“the Fund”), which invested nearly $50 million in a portfolio company run by Christensen’s uncle.
There are a number of compliance deadlines that are already set for 2025. Similarly, the 2025 Exam Priorities published by the Division of Examinations and published observations from the commission will continue to be a guide for effective compliance programs. Start your year off on the right foot with our 2025 Compliance Program Checklist.
On December 26, 2024, a merits panel of the Fifth Circuit Court of Appeals reinstated a nationwide injunction blocking enforcement of the Corporate Transparency Act (CTA) and its required reporting of beneficial ownership information.