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SEC Urges Advisers Relying Upon Unibanco No-Action Letters to Submit Certain Documentation 

As investment advisers eagerly await clarity about the direction the SEC will take in the Trump era and whether it will deviate from past enforcement practices, SEC guidance and information updates on major policy issues face intense scrutiny. One of the most significant publications to come out of the agency since the new administration took office provides specific guidance to multi-national financial institutions relying on the “Unibanco letters,” which concern the extra-territorial application of the Investment Advisers Act of 1940. This update contains valuable information from compliance and procedural standpoints, as the SEC appears to be reminding advisers that rely upon the Unibanco letters about the complex requirements set forth therein. To help readers understand the significance of the information update and its effect on their businesses, this article analyzes the update and provides commentary from legal practitioners with experience representing multi-national advisory firms. For more on the Unibanco letters, see “SEC Delays Registration Deadline for Hedge Fund Advisers, and Clarifies the Scope and Limits of Registration Exemptions for Private Fund Advisers, Foreign Private Advisers and Family Offices” (Jun. 23, 2011).

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