News & Insights

The SEC’s Proposed and Final Rules and Key Dates

The table below outlines the SEC’s current compliance and cyber rule-making, including status, associated dates and links to the proposed, or final, rules.  Full list is found here.

Rule Name Stage of Rulemaking Expected Adoption Date Final Rule Date(s) Link to Proposed or Final Rule
Amendments to Form PF to Require Current Reporting and Amend Reporting Requirements for Large Private Equity Advisers and Large Liquidity Fund Advisers Final Rule Adopted May 2023 December 11, 2023 –Compliance date for new Form PF sections 5 and 6
June 11, 2024 – Compliance date for other updates to Form PF
View Final Rule
Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews Final Rule October 2023 TBD View Final Rule
Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers Final Review October 2023 TBD View Proposed Rule
Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies Final Review October 2023 TBD View Proposed Rule
Outsourcing by Investment Advisers Final Review April 2024 TBD View Proposed Rule
Prohibition Against Fraud, Manipulation, and Deception in Connection With Security-Based Swaps; Prohibition Against Undue Influence Over Chief Compliance Officers Final Review October 2023 TBD View Proposed Rule
Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices Final Review October 2023 TBD View Proposed Rule
Modernization of Beneficial Ownership Reporting Schedules 13D and 13G Final Review October 2023 TBD View Proposed Rule
Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N–PORT Reporting Final Review October 2023 TBD View Proposed Rule
Privacy Act Amendments Final Review October 2023 TBD View Proposed Rule
Investment Company Names Final Review October 2023 TBD View Proposed Rule
Cybersecurity Risk Governance – Public Companies Final Review October 2023 TBD View Proposed Rule
Regulation S P: Privacy of Consumer Financial Information and Safeguarding Customer Information Final Review April 2024 TBD View Proposed Rule
Cybersecurity Risk Management Rules for Broker-Dealers, Clearing Agencies, MSBSPs, the MSRB, National Securities Associations, National Securities Exchanges, SBSDRs, SBS Dealers, and Transfer Agents Final Review April 2024 TBD View Proposed Rule
Rule 144 Holding Period Proposed April 2024 TBD View Proposed Rule
Regulation ATS Modernization Proposed April 2024 TBD Reginfo
Prohibition of Conflicted Practices for Investment Advisers That Use Certain Covered Technologies Proposed TBD TBD Reginfo
Registration for Index-Linked Annuities Proposed TBD TBD Reginfo
Registration for Internet Advisers Proposed TBD TBD Reginfo
Exchange-Traded Products Proposed TBD TBD Reginfo
Registered Investment Company “Fund” Fee Disclosure and Reform Proposed TBD TBD Reginfo

The  dates above are subject to change by the SEC, but regardless the upcoming months are expected to be eventful on the regulatory front.