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9/8/2026 4:24:41 PM

WSJ PPLI Commentary — The Journal Got a Few Things Right

By Henry Bregstein

This week's Wall Street Journal piece on private placement life insurance, "'A Roth IRA on Steroids': Wealthy Americans Find Another...

8/31/2026 2:50:54 PM

The ID-SMA Is No Longer a Concept — It Is a Robust Structure

By Henry Bregstein

For a few years, the insurance-dedicated separately managed account (ID-SMA) was a structure that many advisors had heard about but few...

8/17/2026 6:14:01 PM

The Sunset Is Gone. Income Tax Remains: The PPLI – PPVA Solution.

By Henry Bregstein

For the better part of a decade, every estate planning conversation my colleagues had with a high-net-worth family started with the same...

7/21/2026 2:03:51 PM

IRS Fixes the ‘1035 Exchange Trap’: What Life Settlement Funds and PPLI Users Need to Know Now

By Henry Bregstein Mitchell Fagen

The US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have just finalized regulations fixing a problem that...

6/17/2026 2:51:04 PM

Supreme Court Rejects Implied Private Right of Action Under Section 47(b) of the Investment Company Act of 1940

By Kevin Broughel Sarah Eichenberger Michael Didiuk +2 more...

On June 11, the Supreme Court, in a 6-3 decision authored by Justice Amy Coney Barrett, joined by Justices John G. Roberts, Clarence...

6/16/2026 3:11:41 PM

Show Me the Fees: SEC Risk Alert Zeroes in on Economic Conflicts of Interest

By Adam Bolter Michael Didiuk

The SEC’s Division of Examinations(Division) issued a Risk Alert on June 9, highlighting its observations during a review of the economic...

6/10/2026 8:43:44 PM

CFTC Eliminates ‘No-Deny’ Settlement Policy

By Christian Kemnitz Carl Kennedy Brian Poronsky +2 more...

On June 3, 2026, the Commodity Futures Trading Commission (the CFTC or Commission) rescinded its longstanding policy requiring defendants...

5/19/2026 6:22:02 PM

A Major Change in SEC Enforcement Settlements: SEC Rescinds ‘No-Deny’ Policy

By Susan Light Wayne M. Aaron Michael Diver +3 more...

On May 18, 2026, the Securities and Exchange Commission (SEC) announced that it had rescinded its longstanding “no-deny” (gag) settlement...

5/8/2026 5:51:14 PM

SEC Adopts Inflation-Based Adjustment to 'Qualified Client' Thresholds for Performance Fees

By Michael Didiuk Alexa Warner Adam Bolter

On April 28, 2026, the Securities and Exchange Commission (SEC) issued a final order adjusting for inflation the dollar amount thresholds...

3/23/2026 4:04:57 PM

SEC Chairman Atkins Outlines Vision and Priorities at SIFMA Compliance and Legal 2026 Annual Conference

By Zachary Schmitz Carl Kennedy Matt Kluchenek +1 more...

In a candid fireside chat at the 2026 SIFMA Compliance and Legal Annual Conference, Securities and Exchange Commission (SEC or...

2/4/2026 10:15:30 AM

Digital Asset Exchanges, 24/7 Trading and Collateral Tokenisation: Key Takeaways from the TOK26 Summit

By Christopher Collins

On 29 January 2026, Katten sponsored the London Tokenisation Summit (TOK26) in London, bringing together leading voices in digital assets...

1/23/2026 3:57:46 PM

Marketing Rule Relief for Investment Advisers: SEC Staff Clarifies Flexibility on Model Fees and SRO Disqualifying Events

By Adam Bolter Michael Didiuk

On January 15, Staff from the Securities and Exchange Commission (SEC) published two new frequently asked questions (FAQs) related to the...

1/14/2026 9:40:47 PM

FinCEN Finalizes 2028 Compliance Date for Adviser AML Programs

By Adam Bolter Michael Didiuk

On December 31, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a two‑year delay of the...

1/14/2026 6:58:20 PM

Confidential Treatment for Advisers Act Filings: Process Changes and Practical Takeaways

By Michael Didiuk Adam Bolter

Investment advisers may request confidential treatment of certain information in Form ADV and other filings under the Investment Advisers...

1/13/2026 6:16:11 PM

Defining Small: SEC Proposal Could Shift Regulatory Burdens for Advisers and Investment Companies

By Adam Bolter Michael Didiuk

On January 7, the Securities and Exchange Commission (SEC) proposed amendments (the Proposal) to raise the small entity thresholds for...

12/19/2025 10:38:14 PM

Marketing Rule Under the Microscope: New SEC Exam Findings

By Adam Bolter Michael Didiuk Richard Marshall

The SEC's Division of Examinations' staff (Staff) issued a Risk Alert on December 16, highlighting additional observations on investment...

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WSJ PPLI Commentary — The Journal Got a Few Things Right

The ID-SMA Is No Longer a Concept — It Is a Robust Structure

The Sunset Is Gone. Income Tax Remains: The PPLI – PPVA Solution.

IRS Fixes the ‘1035 Exchange Trap’: What Life Settlement Funds and PPLI Users Need to Know Now

Supreme Court Rejects Implied Private Right of Action Under Section 47(b) of the Investment Company Act of 1940

Show Me the Fees: SEC Risk Alert Zeroes in on Economic Conflicts of Interest

CFTC Eliminates ‘No-Deny’ Settlement Policy

A Major Change in SEC Enforcement Settlements: SEC Rescinds ‘No-Deny’ Policy

SEC Adopts Inflation-Based Adjustment to 'Qualified Client' Thresholds for Performance Fees

SEC Chairman Atkins Outlines Vision and Priorities at SIFMA Compliance and Legal 2026 Annual Conference

Digital Asset Exchanges, 24/7 Trading and Collateral Tokenisation: Key Takeaways from the TOK26 Summit

Marketing Rule Relief for Investment Advisers: SEC Staff Clarifies Flexibility on Model Fees and SRO Disqualifying Events

FinCEN Finalizes 2028 Compliance Date for Adviser AML Programs

Confidential Treatment for Advisers Act Filings: Process Changes and Practical Takeaways

Defining Small: SEC Proposal Could Shift Regulatory Burdens for Advisers and Investment Companies

Marketing Rule Under the Microscope: New SEC Exam Findings

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