Simpson Thacher Partners Author Bloomberg Law Article on Potential Enforcement Changes to SEC Advisers Act Rule 206(4)-8
08.12.25
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Partners Adam Aderton, Justin Browder, Anne Choe and Michael Osnato authored an article titled, “SEC Rule for Investment Advisers on Shaky Ground in Atkins Era,” in Bloomberg Law. The article discussed the SEC’s approach to the enforcement of the Advisers Act Rule 206(4)-8, which has become a mainstay of the SEC’s registered and private fund enforcement program since its adoption in 2007, and how its enforcement may be reassessed with SEC Chairman Paul Atkins back at the agency. The article also explored the background of the rule and Atkins’ objections as a Commissioner at the Rule’s adoption, as well as key takeaways for investment advisers should the SEC raise the bar in enforcing this key rule. Associate Anna Goodnight and Summer Associate Timothy Silva provided valuable assistance with this article.
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