2022 Regulatory Headwinds: Potential Changes to Securities Laws and Regulations and the Impact on Private Fund Managers


Christi James, ACA Group, and Benjamin B. Allensworth, Willkie Farr & Gallagher LLP

Publish Date



  • RegTech
  • Compliance

The U.S. Securities and Exchange Commission (SEC) has signaled a clear shift in focus and prioritization. Recent commentary from SEC Chair Gary Gensler indicates that the agency will likely push forward with an aggressive rulemaking agenda in 2022.

We've partnered with Willkie Farr & Gallagher LLP to explore several of the proposed rulemakings that merit special attention for private funds. In this white paper, we discuss:

  • Environmental, Social, and Governance (ESG) Rulemaking
  • Expanded Reporting Requirements for Investment Advisers
  • Enhanced Regulation for Private Funds
  • Implementation of the Investment Adviser Marketing Rule
  • Regulation of Digital Assets
  • Increased Regulation of Special Purpose Acquisition Companies (SPACs)


How we help

Compliance teams need continuous support and knowledge sharing to stay on top of global regulatory initiatives. Our team helps you navigate the evolving regulatory landscape while considering the complexity of your firm’s unique compliance requirements.

We help our clients manage regulatory compliance, cybersecurity and risk, and performance verification through our consulting, outsourcing, and technology solutions.


If you have questions about any of the topics discussed in this white paper, or would like to find out how ACA can help you build and maintain an effective compliance program, please reach out to your ACA consultant or contact us here.

About the Authors

Christi James

Christi James is a Principal Consultant with ACA Group. Christi brings more than 15 years of experience as a regulatory compliance officer and corporate leader. As a Principal Consultant with ACA’s Investment Adviser Division, Christi works with investment advisers to develop, maintain, and review their compliance policies and procedures. She has extensive knowledge of the Investment Advisers Act of 1940 and FINRA regulations for registered investment companies.

Prior to ACA, Christi served as lead compliance manager in global communications compliance, at T. Rowe Price. There, she acted as a subject matter expert for marketing and regulatory requirements for ETFs, as well as lead compliance manager for new product launches, including separately managed accounts, model portfolios, and collective investment trusts. Previously, Christi has served as a compliance and legal manager with the CR Group, and as a compliance manager with JP Morgan Chase and Invesco.

Benjamin B. Allensworth

Benjamin Allensworth is counsel in Willkie Farr & Gallagher LLP’s Asset Management Group. Ben has more than 19 years of asset management experience that includes private fund and investment adviser formation, formation and regulatory counseling to business development companies, regulatory advice on investment company status and other specialized provisions of the Investment Company Act of 1940, regulatory counseling to investment advisers with respect to securities law matters, and regulatory advice in connection with asset manager M&A transactions.

Prior to rejoining Willkie Farr & Gallagher LLP as counsel, Ben was Managing Director and Counsel at the Managed Funds Association, the global trade association for the alternative investment fund industry. At MFA, he worked with alternative investment managers to provide regulatory advocacy in front of U.S. and EU legislative and regulatory bodies and counseling managers in connection with legislative and regulatory developments. Ben’s advocacy work and counseling to managers included issues under the Advisers Act, the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Jumpstart our Business Startups Act, the Tax Cuts and Jobs Act, and the Alternative Investment Fund Managers Directive. He also provided advocacy and counseling to managers in connection with Department of Labor rulemakings under ERISA.