Both the Senate and House are in recess in a holiday-shortened week. This update includes:
- SIFMA's recent guidance on "Reasonable Steps" for verifying Accredited Investor status in Rule 506(c) general solicitations;
- The conflict between the Senate and House over FY 2015 funding of the SEC;
- A report by the Private Equity Growth Capital Council (PEGCC) describing private equity investment broken down by state and Congressional district;
- The SEC's recent action against a private equity fund for violating federal pay-to-play rules regarding political contributions;
- The SEC's recent order for a tick size pilot plan; and
- Last week's Financial Services Committee hearings on SEC oversight, the Export-Import Bank, and Financial Stability Oversight Council.
Note: The head of the SEC's Office of Compliance Inspections and Examinations recently gave a speech (described below) warning private equity managers about several areas where PE funds are failing to meet their obligations under the Investment Advisers Act. A key problem area is the issue of fees and expenses charged by the general partner.
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