David E. Wohl

• SEC Targets “Greenwashing” by Investment Funds: More Proposals on the SEC ESG Agenda Alert — Governance & Securities — By Lyuba Goltser, Adé Heyliger, Robert Stern, David E. Wohl and John H. Bradshaw — PDF — June 21, 2022
• SEC Issues Risk Alert on Adviser Examination Process and Settles Charges Regarding Advisers’ Marketing Rule Violations Blog Post — Global Private Equity Watch — By David E. Wohl — September 12, 2023
  On September 6, 2023, the SEC’s Division of Examinations issued a risk alert outlining its risk-based approach to selecting advisers for examination and determining focus areas of such examinations. Separately, on September 11, 2023, the SEC announced that it had settled charges against nine investment advisers for publicly advertising hypothetical performance on their websites without adopting and/or implementing policies and procedures as required by amended Rule 206(4)-1 under the Investment Advisers Act of 1940. ...
• SEC Settles Separate Charges Regarding Private Equity Firm’s Inadequate Disclosure of Fee Payments to an Affiliate and Advisers’ Failure to Comply with Custody Rule Blog Post — Global Private Equity Watch — By David E. Wohl — September 08, 2023
  On September 5, 2023, the SEC announced settlements related to separate charges against (i) a real estate focused private equity firm for failing to adequately disclose to investors millions of dollars of real estate brokerage fees that were paid to an affiliate, and (ii) a group of investment advisers for failing to comply with the requirements of Rule 206(4)-2 under the Advisers Act. ...
• SEC Adopts Significant New Rules Regarding the Regulation of Private Fund Advisers Blog Post — Global Private Equity Watch — By David E. Wohl and John H. Bradshaw — August 24, 2023

  On August 23, 2023, the SEC adopted new rules under the Investment Advisers Act of 1940 (the Advisers Act) that significantly increase the regulation of private fund advisers.[1]  As previewed by the SEC’s original February 2022 proposal, the final rules establish a more prescriptive, rules-based regulatory regime for private fund advisers designed to protect investors […]

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• Application of FinCEN’s Final Rule Regarding the Corporate Transparency Act’s Beneficial Ownership Reporting Requirements to Investment Advisers and Private Funds Blog Post — Global Private Equity Watch — By Andrew I. Chizzik, Timothy C. Welch and David E. Wohl — August 21, 2023

  The Financial Crimes Enforcement Network’s (“FinCEN”)[1] final rule implementing the beneficial ownership information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”) will become effective on January 1, 2024 (“Effective Date”).[2] The final rule requires certain U.S. domestic and foreign companies (“Reporting Companies”) to report BOI to FinCEN with respect to (i) any natural persons […]

  The post Application of FinCEN’s Final Rule Regarding the Corporate Transparency Act’s Beneficial Ownership Reporting Requirements to Investment Advisers and Private Funds appeared first on Global Private Equity Watch.

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