While the pace of rulemaking by the SEC slowed dramatically in the 3rd quarter of 2024, following legal challenges that overturned major rulemaking initiatives, the pace of enforcement actions accelerated as the SEC raced toward the end of its 2024 fiscal year. There were many notable enforcement actions filed in the final month of the fiscal year as well as some key personnel developments.

In early October, the SEC issued a Frequently Asked Questions (FAQ) document related to the compliance date of the amendments to Form PF adopted under the “Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers” rule. The FAQ confirmed the filing deadline for the amended form for annual filers and quarterly filers. The FAQ also clarified that large filers whose fiscal quarter does not end on a calendar quarter end will be required to transition from a fiscal quarter reporting schedule to calendar quarter reporting.

The Standish Compliance team continues to track and analyze regulatory developments and their impact on our private fund and other clients. Let us know if you have questions regarding any recent regulatory developments or their application to your firm.