Rimon attorneys will be in Copenhagen, October 4-9, 2026, for the IBA Annual Conference, and we welcome the opportunity to connect with fellow attorneys from across the global legal community. If you will be in Copenhagen and would like to meet to discuss collaboration opportunities, cross-border work, or simply connect, please reach out to us.…

The compliance date for the SEC’s amendments to Regulation S-P has now passed for all covered firms: December 3, 2025 for larger entities, and June 3, 2026 for smaller entities -including registered investment advisers with less than $1.5 billion in assets under management. Advisers that have not yet implemented the required policies and procedures are…

Effective June 29, 2026, the U.S. Securities and Exchange Commission (the “SEC”) increased the dollar-amount thresholds used to determine “qualified client” status under Rule 205-3 of the Investment Advisers Act of 1940. The SEC adjusts these thresholds for inflation every five years; the current order is available here: https://www.sec.gov/files/rules/ia/2026/ia-6961.pdf. What changed: Assets-under-management test: increased from…

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide order prohibiting the Treasury Department/Financial Crimes Enforcement Network (FinCEN) from enforcing the Corporate Transparency Act (CTA). This is, however, only a preliminary injunction and not a final decision – and FinCEN has indicated it would appeal this decision. …

The Division of Examinations of the Securities and Exchange Commission has recently announced its 2024 Examination Priorities. These include: Focus on compliance with Adviser’s fiduciary duty standard and the management of conflicts.  The Staff noted that it will be examining for advisers’ adherence to their duty of care and duty of loyalty obligations to clients. …

Rimon congratulates its client, E2M Ventures (“E2MV”) on the closing of a $50mm capital facility with Crayhill Capital Management LP (Crayhill). The facility is expressly designed to facilitate E2MV’s ability to offer “gap financing” solutions to real estate sponsors primarily across the Central and Western United States. The program will enable E2MV to provide sponsors access…

The SEC’s Division of Examinations has recently issued a risk alert regarding the revised Marketing Rule (Rule 206(4)-1). The compliance date for the Marketing Rule is November 4, 2022 (Compliance Date). As of the Compliance Date, investment advisers may no longer choose to comply with the previous advertising and cash solicitation rules. Registered investment advisers,…

A few notes from the recently held American Bar Association Business Law Section Annual meeting, where we heard from two key decision-makers from the Securities and Exchange Commission: First, last Wednesday, Hester Peirce, a Commissioner from the U.S. Securities and Exchange Commission spoke at the Blockchain, Cryptocurrencies and Investment Management Task Force Meeting. I was…

On January 27, 2021 the Division of Examinations of the Securities and Exchange Commission published their second risk alert focused on Private Fund Advisor deficiencies commonly noted in connection with their examinations. These include: Conduct Inconsistent with Disclosures Failure to obtain informed consent from Limited Partner Advisory Committees, Advisory Boards or Advisory Committees (collectively “LPACs”)…

The SEC’s Office of Compliance Inspections and Examinations recently published a risk alert related to investment advisers managing Digital Assets for their clients, either directly or indirectly through pooled investment vehicles.  The risk alert makes it clear that digital assets create a number of unique compliance challenges that firms should consider. Based upon risks identified…