On August 18, 2026, the Commodity Futures Trading Commission (“CFTC”) published a Notice of Proposed Rulemaking seeking public comments on amendments to part 4 of the CFTC’s regulations (the “Proposal”). See notice here: CFTC Seeks Public Comment on Proposed Rule Changes for Commodity Pool Operator and Commodity Trading Advisor Registration | CFTC. The Proposal builds…

On August 31, 2026, the U.S. Securities and Exchange Commission (“SEC”)  and the Commodity Futures Trading Commission (“CFTC”) announced that they are further extending the compliance date for the amendments to Form PF that were adopted on February 8, 2024, from October 1, 2026, to July 1, 2027. See announcement here: SEC.gov | Statement on…

On July 28, 2026, the National Futures Association (“NFA”) sent a reminder to its member firms about its upcoming fingerprint procedure changes effective October 1, 2026. The changes will require fingerprint submissions to NFA to be submitted through Fieldprint, NFA’s newly designated fingerprint service provider. See reminder here: NFA News Center | NFA To comply…

Rimon attorneys will be in San Francisco for Funds Week October 12-15.  Our team will be attending a range of Funds Week events, and we will additionally be hosting the SF Funds Week walk on October 12 at 5:00pm. If you’ll be attending SF Funds Week, please reach out to us. We look forward to…

Regulation E-Delivery On July 21, 2026, the U.S. Securities and Exchange Commission (“SEC”) proposed Regulation E-Delivery. The proposed rule will allow covered entities to electronically deliver covered information to covered recipients without prior affirmative consent, under certain conditions. It also defines when electronic delivery satisfies federal securities law delivery requirements. Additionally, the SEC proposes rescinding…

On July 22, 2026, SEC Commissioner Hester Peirce issued a statement (the “Statement”) on when certain asset deployment tools such as crypto “vaults” and onchain lending strategies implicate federal securities laws.[1] The Statement’s organizing principle is familiar: moving an activity onchain does not move it outside U.S. securities laws.[2] It maps common vault and lending-strategy features to specific regulatory categories,…

On April 20, 2026, the U.S. Securities and Exchange Commission (“SEC”)  and the Commodity Futures Trading Commission (“CFTC”) jointly proposed to amend Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, including those that also are registered with the CFTC as commodity pool operators or commodity trading advisors. You can read the press release here: SEC.gov…

The SEC’s amendments to Regulation S-P, adopted May 16, 2024, substantially expanded privacy obligations for certain covered institutions, which includes SEC registered investment advisers (RIAs). Large RIAs (≥$1.5 billion in regulatory assets under management) had to comply since December of 2025 and smaller RIAs must comply effective June 3, 2026. There are five key tenets of the amendment: Expanded definition of information covered by the…

The California Fair Investment Practices by Venture Capital Companies Law (“FIPVCC”) was passed in 2023 and later amended in 2024. The initial registration and reporting deadlines under the FIPVCC are quickly approaching. Starting March 1, 2026, the operative provisions of FIPVCC go into effect. The FIPVCC requires a “Covered Entity” to register with the California Department of Financial Protection and Innovation…

On December 19, 2025, the staff of the CFTC’s Market Participants Division (“MPD”) issued CFTC No-Action Letter 25-50 that grants no-action relief (the “No-Action Relief”) from registration as a commodity pool operator (“CPO”) and commodity trading advisor (“CTA”) for eligible investment managers1 with respect to qualifying private funds where the following conditions are satisfied: SEC…