News & Resources

DOWNLOAD PDF SEC MARKETING RULE – RULE 206(4)-1 In December 2020, the SEC materially reformed rules governing the marketing practices of investment advisers, including rules governing an adviser’s fund-raising efforts for private investment funds – funds excluded from regulation under the Investment Company Act of 1940 (“1940 Act”).1 NOVEMBER 4… [Click to Read More]

McIntyre & Lemon submitted a comment letter on behalf of certain portfolio-management clients to address the SEC’s recently proposed dealer rules and the potential for them to capture portfolio-management firms. Click here to review the comment letter.

McIntyre & Lemon submitted a comment letter today to address the SEC’s recently proposed dealer rules. We submitted comments on behalf of a constituency of professional equity trading firms that could be affected by a proposed expansion of dealer registration and regulation to reach exempt securities traders. Click here to… [Click to Read More]

INTRODUCTION Unregistered trading funds and discretionary asset managers have historically operated in the asset management sector and not as securities dealers subject to the comprehensive broker-dealer regulatory regime of the Securities Exchange Act of 1934 (“Exchange Act”) and rules of self-regulatory organizations (“SROs”). The Securities and Exchange Commission (“SEC” or… [Click to Read More]

DOWNLOAD PDF REGULATORY PROPOSAL Over the past decade, the Securities and Exchange Commission (“SEC”) and its staff have addressed cybersecurity threats and their escalating risk to commerce. Routinely cited as an examination priority, the SEC has now proposed standardized disclosure requirements of material cybersecurity events and cybersecurity protocols for public-reporting… [Click to Read More]