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    Mar. 26, 2026

Compliance Corner Q2‑2026: Regulatory Filings and Other Considerations Hedge Fund Managers Should Note in the Coming Quarter

This installment of the Hedge Fund Law Report’s quarterly compliance update highlights key upcoming filing deadlines and reporting requirements fund managers should be aware of during the second quarter of 2026. This guest article by ACA Group consultants Jeremy Heckerling, Elli Kavros, Jennifer Rodriguez and Ken Carroll also discusses the requirements under the newly enacted Holding Foreign Insiders Accountable Act and updates to the SEC’s Marketing Rule FAQs addressing net performance and promoter disqualification. ACA Group’s 2026 regulatory filings calendar, which is designed to help fund managers stay on top of important filing obligations, is available here. For more from ACA Group, see “Preparing for and Navigating SEC Examinations” (Dec. 19, 2024).

Making Use of CFTC No‑Action Relief Restoring Commodity Pool Operator Exemption (Part Two of Two)

Many in the private funds industry have reacted positively to the Market Participants Division of the CFTC’s issuance of December 19, 2025, No‑Action Letter 25‑50 (Letter) that restores an exemption from CFTC registration for commodity pool operators (CPOs) and commodity trading advisors (CTAs). But as welcome as it may be, the Letter was not drafted with all CPOs and CTAs in mind. Depending on their operations, strategy and risk exposure, some will find it to be of greater utility than others. “Stepping down,” i.e., relying on the no‑action relief and/or deregistering, comes with broad disclosure responsibilities. Moreover, whether to step down, before rulemaking codifies the Letter into law, requires careful consideration. This article, the second in a two-part series, considers which types of asset managers are the likeliest beneficiaries of the Letter’s relief; addresses the reporting and disclosure requirements of those that opt to deregister to take advantage of the new relief; and weighs the pros and cons of taking action now in the absence of formal rulemaking. The first article explained the background of and rationale for the CFTC’s no‑action position and summarized the Letter. For more on the CFTC’s revisitation of legal precedent, see “CFTC Advisory on Self-Reporting, Cooperation and Remediation Overhauls Years of Guidance” (Mar. 27, 2025).

A U.S. Fund Manager’s Perspective on AIFMD 2.0

As the April 2026 implementation date for the recast Alternative Investment Fund Managers Directive (AIFMD and, as recast, AIFMD 2.0) draws closer, U.S. private fund managers face a targeted shift in the E.U. fund regulatory landscape that requires careful consideration and planning. Although AIFMD 2.0 amounts more to a series of targeted amendments than a complete overhaul of the existing AIFMD framework, a number of changes will be of particular importance to U.S. fund managers marketing into or otherwise operating in Europe. This guest article by Sidley attorneys Leonard Ng and Arash Dashtgard focuses in detail on two specific changes introduced under AIFMD 2.0: amendments to the conditions to marketing under the National Private Placement Regime and the introduction of a harmonized E.U. regime for direct lending (or “loan originating”) funds. In addition, this article briefly discusses other changes relevant to U.S. fund managers, including revisions to the delegation regime and the expansion of the information required under the investor disclosure and regulatory reporting requirements. See “U.K. Regulators Propose Changes to AIFM Rules to Ease Compliance Burden on Fund Managers” (Sep. 25, 2025).

Alternative Data and AI Becoming Integral to Investment Processes, Survey Finds

On February 19, 2026, Lowenstein Sandler issued the results of its sixth annual alternative data study (Report). “Our survey suggests that alternative data has become a foundational element of investment research,” Scott Moss, a Lowenstein Sandler partner and co-author of the Report, told the Hedge Fund Law Report. The growth may be due to increasing integration of artificial intelligence (AI). Although AI accelerates firms’ ability to generate insights and uncover alpha, it increases the need for strong governance, model risk oversight and clear data provenance, Moss noted. Firms face “a more complex commercial and governance environment with higher costs, tighter licensing terms and greater restrictions on AI-related data usage, particularly for model training,” he added. The latest survey examined the growing uptake of alternative data and AI; how firms are applying AI to alternative data; data sources; key risks and concerns; and budgeting. This article parses the Report, with additional commentary from Moss and the Report’s other co-authors, Lowenstein Sandler partner Boris Liberman and counsel George Danenhauer. See our coverage of Lowenstein Sandler’s 2023, 2022, 2021 and 2019 alternative data surveys.

SEC Chair Atkins Discusses “Project Crypto”

SEC Chairman Paul S. Atkins makes no effort to hide his disapproval of the approach to digital assets taken by his predecessors at the SEC. He has wholeheartedly embraced the Trump administration’s desire to bring the digital asset ecosystem into the mainstream. In 2025, Atkins announced the SEC’s Project Crypto initiative, saying it will serve as the agency’s “north star in aiding President Trump in his historic efforts to make America the ‘crypto capital of the world.’” Atkins, together with Commissioner Hester M. Peirce, who leads the SEC’s Crypto Task Force, have been developing a plan for “crypto market primacy.” On November 12, 2025, Atkins gave a speech at the Federal Reserve Bank of Philadelphia in which he provided additional details on Project Crypto and the SEC’s efforts to promote U.S. leadership in digital finance. Project Crypto “is a commitment to humility about the SEC’s own reach,” he said. The securities laws “were not designed as a universal charter to regulate every novel form of value, digital or otherwise,” he asserted. As usual, the views expressed were his own, not those of the SEC or any of its commissioners. This article distills his remarks. See “NSCP to SEC’s Crypto Task Force: Focus on Clarity, Custody and Coordination” (Nov. 20, 2025).

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Trailblazing Women – Contributions, Achievements and Observations of Outstanding Leaders

To mark International Women’s Day, Law Report Group editors, along with our colleagues across ION Analytics’ products, interviewed outstanding women in the industries and jurisdictions we cover. In this article, Jill Abitbol, Robin Barton, Rorie Norton and Megan Zwiebel profile notable women in the data privacy, cybersecurity, AI, private funds and anti-corruption law fields, including (i) Paula Howell Anderson, (ii) Gwendolyn Lee Hassan, (iii) Audrey Koh, (iv) Stacy Feuer, (v) Heather Egan, (vi) Jeewon Serrato, (vii) Stephanie Breslow, (viii) Anne Choe, (ix) Heather Wyckoff, (x) Angie Batterson, (xi) Jacqueline Eaves, and (xii) C. Dabney O’Riordan.

Enjoy reading their inspiring remarks here.