On Feb. 6, 2024, the US Securities and Exchange Commission ("SEC" or "Commission") adopted new Rules 3a5‑4 and 3a44‑2 (together, "Final Rules").
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SEC-registered investment advisers are subject to an array of reporting and compliance obligations in order to maintain registered investment adviser status.
On February 6, 2024, the SEC adopted rules to greatly expand the Exchange Act definitions of "dealer" and "government securities dealer" by further defining the phrase "as a part of a regular business."