Daniel Leonardo

Chief Compliance Officer and Deputy General Counsel @multicoinCap opinions are my own / not a solicitation / not an offer for investment advisory services

[Daniel Leonardo @_DanLeonardo]

As an SEC alum, I am again hopeful for the future of the institution and the markets it oversees.

[Daniel Leonardo @_DanLeonardo]

The now confirmed nomination of Paul Atkins to be the next SEC Chair begins a long process of healing the damage done to the SEC during the Gensler era (my colleague @Xethalis summarizes below why everyone in crypto should be excited about his nomination).  The SEC suffered

[Greg Xethalis @xethalis]

Today, President Trump is expected to announce his nomination of Paul S. Atkins to be Chair of the SEC (pending Truth Social confirmation). This is welcome news to the crypto industry and US capital markets.

[Daniel Leonardo @_DanLeonardo]

a massive brain drain during the Gensler years.  It will be difficult to replace and replicate that talent in the short term, but I am confident that Atkins will create an environment where the SEC can once again regain both the confidence of market participants and its staff.

[Daniel Leonardo @_DanLeonardo]

8/ Until we see an appellate decision specifically rejecting such cases, I think the SEC will continue to bring actions under Section 206(4) for noncompliance of the LPA/PPM.

[Daniel Leonardo @_DanLeonardo]

1/ Private fund CCOs keep your guard up. Notwithstanding the recent 5th Circuit opinion vacating PFAR, the SEC (both ENF and EXAMS) will continue to bring cases/deficiencies against private fund advisers under Section 206(4). A 🧵…

[Daniel Leonardo @_DanLeonardo]

7/ Although it notes that 206(4) doesn’t authorize the SEC to require disclosure, IMO, that is not the same as stating that the SEC cannot bring enforcement actions under 206(4) for noncompliance (or lack of disclosure) in the LPA/PPM.

[Daniel Leonardo @_DanLeonardo]

15/15 - link https://t.co/FgF1SpBCWY

[Daniel Leonardo @_DanLeonardo]

1/15 Last week the 5th Cir. vacated the Private Fund Adviser rule (PFAR) on the grounds that the SEC, in enacting the rule, exceeded its statutory authority. Congratulations to our friends at @AIMA_org and their co-plaintiffs on the ruling. The SEC has until late June to appeal.

[Daniel Leonardo @_DanLeonardo]

15/15 workable proposals in this and other areas. Adviser custody practices should be updated and incorporate guidance for digital assets, but, as the internet once said, “this ain’t it, Chief.”