Iron Road Partners

Many of our clients have wrestled with the decision of whether to keep marketing reviews in-house or whether to outsource them—and it’s a more complex decision than it initially seems. One thing we have observed is that the true cost of managing this function internally is frequently underestimated. Through our client work and insights from our marketing review business, we have identified common challenges and hidden costs that tend to get overlooked. We have put together a straightforward infographic that outlines the key components and tradeoffs involved in the decision. #regulation #sec #marketing #advertising #LPcommunications You can download our infographic here: https://lnkd.in/eGDN8cMc

Join your colleagues on 𝗠𝗮𝗿𝗰𝗵 𝟮𝟱, 𝟮𝟬𝟮𝟱, 𝗮𝘁 𝟮 𝗣𝗠 𝗘𝗧 for Regulatory Compliance Watch, co-hosted with Private Funds CFO- 𝗣𝗿𝗶𝘃𝗮𝘁𝗲 𝗳𝘂𝗻𝗱𝘀 𝗮𝗻𝗱 𝘁𝗵𝗲 𝗦𝗘𝗖 𝗶𝗻 𝗧𝗿𝘂𝗺𝗽 𝟮.𝟬. Industry experts Greg Baker from Patterson Belknap Webb & Tyler LLP and Emilie Abate from Iron Road Partners, moderated by Bill M., will provide essential insights on preparing for 𝗦𝗘𝗖 exams and the changing landscape of enforcement following Trump’s second term. Register to earn 𝟭 𝗖𝗟𝗘/𝗖𝗣𝗘 credit: https://okt.to/mW6SEt #RegulatoryCompliance #PrivateFunds #𝗦𝗘𝗖 #TrumpAdministration #Compliance #CLE

The SEC's Marketing Rule for Investment Advisers and associated guidance left ambiguities about whether extracted performance and certain non-performance metrics, traditionally shown gross of fees, can still be presented that way. Today, the SEC updated the Marketing Rule FAQs addressing those ambiguities. While this guidance permits the removal of net returns in specific situations, it comes with certain conditions that you must consider if you decide to utilize it. #SEC #marketing #regulation You can find the FAQ here: https://lnkd.in/exMcfnX7 You can find our note here: https://lnkd.in/e4fZkBqr

Today, the #SEC’s Division of Corporation Finance issued a No-Action Letter addressing a key uncertainty in Rule 506(c), which permits general solicitation for private offerings, provided the issuer verifies that all purchasers are accredited. Previously, the SEC had not clearly defined the steps required to verify accredited investor status, leaving issuers uncertain about compliance. This No-Action Letter provides some clarity, stating that a high minimum investment amount, coupled with investor representations, may serve as a reasonable basis for verification. Of note is the speed of approval — the incoming letter was dated on March 6th 2025 and the No-Action relief was issued on March 12th 2025. You can find our note here: https://lnkd.in/eGDN8cMc You can find the No-Action letter here: https://lnkd.in/gzSvahhm

We’re delighted to welcome Jen Conwell to our firm as a Director! Her arrival reinforces our commitment to attracting and retaining top-tier talent—enabling us to tackle complex regulatory challenges and collaborate with investment managers across the spectrum, from smaller SEC registrants to the world’s most sophisticated firms. Welcome, Jen! #Leadership #InvestmentManagement #NewHire https://lnkd.in/eHJJNbii

Please join our Managing Director, Emilie Abate in this important discussion.

Last week, the SEC initiated its first private funds enforcement action under the new administration, unsurprisingly centering on expense-related issues. While it may seem counterintuitive, regulatory scrutiny of private fund expense practices could intensify as attention shifts away from more intricate private fund matters.   Additionally, this case serves as a reminder of the critical importance of risk-based expense testing, which should be tailored to the specific risks associated with each investment adviser. #SEC #Enforcement #Expenses You can download our note here: https://lnkd.in/eGDN8cMc You can download the SEC orders here: https://lnkd.in/e6x2gRxw

Jamie Peterson was quoted in Barron's Advisor sharing his thoughts on the uncertain future of the #DOL Fiduciary Duty rule. “I think it’s highly unlikely that DOL chooses to defend the rule,” says Jamie Peterson, managing director at the compliance consultancy Iron Road Partners. “It’s been a highly politicized rule whose support ebbs and flows every time there’s a change from a Democratic to a Republican—and vice versa—administration,” he says. “I think that the two-month freeze is likely the first step in moving to abandon the rule.” https://lnkd.in/eDEScCiU

During his address before the Florida Bar, Acting Chairman Mark Uyeda outlined a traditional agenda for securities regulation under the current administration. Notably, he emphasized two key rulemaking priorities: revising the accredited investor definition and expanding opportunities for retail investors to participate in private companies and funds. #SEC #financialregulation https://lnkd.in/ed5mJ2X8