May 2026 – Global Investment Law Watch

United States: SEC’s Updated Qualified Client Standards Take Effect 29 June 2026

May 29 2026

By: Sasha Burstein, Pablo J. Man, Mark T. Heine, Edward T. Dartley, and George Zornada

The United States Securities and Exchange Commission’s (SEC) inflation adjustment to the qualified client thresholds under Rule 205-3 of the Investment Advisers Act of 1940 will become effective on 29 June 2026, and will carry important implications for SEC-registered investment advisers (RIAs) that charge performance-based compensation tied to capital gains or investment appreciation.

United States: The SEC Finally Admits It, The No-Admit/No-Deny Policy Is Gone

May 19 2026

By: Thoreau Bartmann, Meghan Flinn, Ted Kornobis, Hayley Trahan-Liptak, and Neil Smith

On 18 May 2026, the United States Securities and Exchange Commission (SEC) rescinded the rule barring settling defendants from publicly denying the agency’s allegations. The policy, in place since 1972, effectively silenced settling defendants on pain of having their cases reopened. Now, defendants can publicly dispute SEC allegations, including under existing consent judgments.

United States: Keeping Up Tradition: Director Woodcock’s Signals a Continuation of Recent Enforcement Priorities

May 18 2026

By: Meghan E. Flinn, Hayley Trahan-Liptak, Thoreau A. Bartmann, and Steve G. Topetzes

One week into the role, new Securities Exchange Commission (SEC) Enforcement Director David Woodcock used his first public remarks to reinforce the enforcement tone set by Chairman Atkins: “quality over quantity” and “back to basics.”

Europe: Ireland’s Private Funds Regime Gets a Major Overhaul: Central Bank Publishes Revised AIF Rulebook

May 06 2026

By: Gayle Bowen and Shane Geraghty

The Central Bank of Ireland (the Central Bank) today published its long-awaited revised AIF Rulebook, consolidating and modernising the regulatory framework for Irish alternative investment funds (AIFs). The revised Rulebook introduces a number of important flexibilities that will be welcomed by industry and will provide greater flexibility to investment managers when structuring their investment funds to better meet investors’ needs.

United States: Private Equity Sunshine Act (SB 1319)

May 04 2026

By: Sasha Burstein, Ami R. Jani, Andrew J. Feucht III, Mark T. Heine, Daniel F.C. Crowley, Karishma S. Page, J. Matthew Mangan, and Ruth E. Delaney

California legislators are advancing the proposed Private Equity Sunshine Act (SB 1319) amending the California Public Records Act to require expanded disclosure by California public investment funds, including state and local pension systems, regarding their alternative investments. The bill would affect both public pension investors and fund managers with California public pension plans as investors.

Archive:May 2026