The SEC Family Office Exclusion After Archegos: What Family Offices Still Disclose

The Exclusion Everyone Misreads

"Family offices don't have to disclose anything" is one of the most loosely repeated claims in wealth management. It points at something real. Since 2011, a single family office that meets the SEC's definition is not an "investment adviser" under the Investment Advisers Act of 1940. It does not register, files no Form ADV and owes no Form PF. Next to the data that registered advisers produce, a qualifying family office can look like a hole in the map.

The exclusion is narrower than its reputation, though. It takes a family office out of one statute's registration framework. It does not take it out of the Securities Exchange Act of 1934, where most public-market disclosure obligations live. A family office with $100 million or more of listed equities under its discretion files Form 13F. One that crosses 5% of a listed company's voting stock files Schedule 13D or 13G on the same shortened deadlines as anyone else. One that trades heavily enough registers with the SEC as a large trader.

The real gaps are elsewhere: in derivatives, and in the fact that each counterparty sees only its own slice of a client's book. The collapse of Archegos Capital Management in March 2021 exposed both. According to the SEC's complaint, Archegos was a family office relying on the exclusion that built exposure equal to more than half the outstanding shares of several listed companies, mostly through total return swaps, while keeping its direct stock holdings below the 5% disclosure threshold.

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Part I: What the Exclusion Is and Who Qualifies

Why the rule exists

Before Dodd-Frank, most family offices relied on the Advisers Act's "private adviser" exemption for advisers with fewer than 15 clients. Dodd-Frank repealed that exemption to bring hedge fund and other private fund advisers under SEC registration. Without a replacement, most family offices would have had to register too.

Section 409 of Dodd-Frank supplied the replacement. Advisers Act Section 202(a)(11)(G) now excludes from the definition of investment adviser "any family office, as defined by rule, regulation, or order of the Commission." The SEC adopted that definition on June 22, 2011, as Rule 202(a)(11)(G)-1 (Release IA-3220; Press Release 2011-134). Offices that did not meet it by March 30, 2012 had to obtain an exemptive order or register. Existing exemptive orders were not rescinded.

Two design features matter. First, this is an exclusion, not an exemption. A qualifying office is not an investment adviser at all for Advisers Act purposes, so registration, Form ADV and the Act's reporting regime do not apply. Second, the rule has no size limit. An office managing $50 million and one managing $50 billion are treated the same if they meet the structural tests.

The three conditions

Under paragraph (b), a family office is a company that:

1. Has no clients other than family clients. A proviso covers involuntary transfers: a non-family person who becomes a client through the death of a family member or key employee, or another involuntary transfer from them, counts as a family client for one year after legal title passes.
2. Is wholly owned by family clients and controlled, directly or indirectly, exclusively by family members and/or family entities.
3. Does not hold itself out to the public as an investment adviser.

All three must hold continuously. One outside client, one outside owner, or marketing advisory services to the public takes the office out of the exclusion.

Who counts as a family client

Family members are defined by a common ancestor, living or deceased, no more than 10 generations removed from the youngest generation of family members. The term covers that ancestor's lineal descendants, including adopted children, stepchildren, foster children and certain minors under a family member's guardianship, plus their spouses or spousal equivalents. The SEC dropped an earlier proposal to define the family by a wealth-creating founder. The family chooses the common ancestor, and that choice sets the family's boundary.

Former family members are spouses, spousal equivalents and stepchildren who stopped being family members through divorce or a similar event. They stay family clients but cannot be among those who control the office.

Key employees are executive officers, directors, trustees, general partners or people in similar roles at the family office or an affiliated family office. Also included are other employees who participate in the office's investment activities and have done so for at least 12 months, counting similar work elsewhere. Employees performing solely clerical, secretarial or administrative functions do not qualify.

Entities include estates of these people, certain charitable organizations funded exclusively by family clients, certain trusts, and companies wholly owned by and operated for the sole benefit of family clients.

The control test

Ownership and control are tested separately. Any family client, including a key employee, may own part of the office. But it must be controlled by family members and/or family entities, and for this purpose the rule excludes key employees and their trusts from "family entity." Control means the power to exercise a controlling influence over the company's management or policies, unless that power comes solely from being an officer. A non-family chief executive can run the office day to day. Governance documents that give non-family parties a controlling influence over its management or policies take the office outside the rule.

What falls outside

• Multi-family offices. Two unrelated families have no single common ancestor. Multi-family offices that give investment advice generally register, which is why they appear in Form ADV data and single family offices do not.
• Outside co-investors. Friends, business partners or former colleagues investing through an office-managed vehicle are non-family clients.
• Holding out. Marketing advisory services, even informally, breaks the third condition.

Paragraph (c) grandfathers certain advice given before January 1, 2010. An office that qualifies only through that grandfathering is still treated as an investment adviser for the antifraud provisions in Advisers Act Sections 206(1), 206(2) and 206(4).

The exclusion also reaches the states

Advisers Act Section 203A(b)(1)(B) provides that no state law requiring registration, licensing or qualification of an investment adviser applies to a person not registered because it is excepted from the definition under Section 202(a)(11). A qualifying family office therefore cannot be required to register with a state either. Section 203A(b)(2) preserves state regulators' power to investigate and bring enforcement actions for fraud or deceit. The exclusion removes registration, not antifraud law.

A recognized investor category

The SEC now uses the definition as a status in its own right. In August 2020 (Press Release 2020-191), it added family offices and their family clients to the "accredited investor" definition in Rule 501(a). An office qualifies if it falls within Rule 202(a)(11)(G)-1, has more than $5 million in assets under management, was not formed to acquire the securities offered, and its investment is directed by a person with sufficient knowledge and experience. On May 1, 2026, the Private Investor Coalition, a group that has described its members as single family offices, petitioned the SEC to extend similar treatment to the "qualified institutional buyer" and "qualified purchaser" definitions.

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Part II: What a Family Office Must Still Disclose

The obligations below mostly come from the Exchange Act. They do not depend on adviser registration. They attach to investment discretion, beneficial ownership and trading activity.

Form 13F: the quarterly snapshot

Section 13(f) requires quarterly reports from every "institutional investment manager" exercising investment discretion over at least $100 million of Section 13(f) securities. The statute defines that term to include any person other than a natural person investing for its own account, and any person exercising investment discretion over another person's account. A family office is an entity that does one or both. Under Rule 13f-1, the test is applied on the last trading day of any month in a calendar year. A manager that meets it makes four filings: one for the December quarter of that year and one for each of the first three quarters of the following year, each within 45 days after quarter end. According to the SEC staff's Form 13F FAQ, the deadlines for the four 2026 quarters are May 15, August 14 and November 16, 2026, and February 16, 2027.

Three limits matter:

• Scope. Only securities on the SEC's Official List of Section 13(f) Securities are reported, mainly U.S. exchange-traded stocks, closed-end fund shares and ETF shares. Over-the-counter total return swaps, private funds, private companies, real estate and most debt do not appear.
• Long positions only. Short positions are not reported, and synthetic longs held through swaps are invisible.
• Confidential treatment. Section 13(f)(4) bars public disclosure of information identifying securities held by the account of a natural person or an estate or trust (other than a business trust or investment company). The SEC staff calls this the "personal holdings exemption," and confidential treatment on that basis can last indefinitely, although the manager still files quarterly. Managers can also request time-limited confidential treatment for commercially sensitive positions. A family office's public 13F can therefore be incomplete.

Schedules 13D and 13G: the 5% line, now faster

Sections 13(d) and 13(g) require anyone beneficially owning more than 5% of a class of registered voting equity securities to file publicly: Schedule 13D for investors with control intent, the short-form Schedule 13G for eligible investors without it.

On October 10, 2023 (Release 33-11253; Press Release 2023-219), the SEC shortened initial deadlines that had not changed since 1968 for 13D and 1977 for 13G:

• 13D: initial filing within five business days (previously 10 days); amendments within two business days.
• 13G, qualified institutional and exempt investors: within 45 days after the end of the calendar quarter in which 5% is crossed (previously 45 days after year end).
• 13G, passive investors: within five business days (previously 10 days).
• 13G amendments: generally 45 days after the quarter in which a material change occurred, with faster amendments when qualified institutional or passive investors exceed 10% or move by 5%.

The filing cut-off moved from 5:30 p.m. to 10:00 p.m. Eastern, and filings must use a machine-readable format. The new 13G deadlines applied from September 30, 2024, and structured data from December 18, 2024.

The 13G route matters for family offices. The relevant qualified-institution category in Rule 13d-1(b) covers investment advisers registered under Advisers Act Section 203 or state law, so an excluded family office does not use it. It generally files either as a passive investor under Rule 13d-1(c), with no control purpose, below 20% and on the five-business-day deadline, or as an exempt investor under Rule 13d-1(d), for holders above 5% who were not required to file under Rule 13d-1(a), on the quarterly deadline. A 13G filer that develops control intent must file a 13D within five business days and may not vote or buy more shares until 10 days after that filing.

The 2023 release also addressed derivatives. It amended Item 6 of Schedule 13D to require disclosure of all derivative securities, including cash-settled ones, that reference the issuer's equity. It gave guidance on when cash-settled derivatives other than security-based swaps can confer beneficial ownership under Rule 13d-3, similar to 2011 guidance on swaps. It also said a "group" can form through concerted action without an express agreement.

The statutory limit is unchanged. Under Exchange Act Section 13(o), a person is deemed to acquire beneficial ownership through a security-based swap only to the extent the SEC determines by rule that the swap provides incidents of ownership comparable to direct ownership. Item 6 requires a 13D filer to disclose its swaps. A cash-settled swap on its own does not generally trigger the filing.

Section 16: the 10% insider regime

A family office that beneficially owns more than 10% of a class of registered equity securities is a Section 16 insider. It must report changes in ownership, including purchases and sales of security-based swap agreements involving that security, before the end of the second business day after the transaction. This is one of the few public regimes that captures swap transactions explicitly, and only after the 10% line is crossed.

Form 13H: large trader, reported confidentially

Section 13(h) and Rule 13h-1 (adopted July 2011) require anyone exercising investment discretion over accounts whose NMS-security transactions reach the "identifying activity level" to file Form 13H. That level is two million shares or $20 million in a calendar day, or 20 million shares or $200 million in a calendar month. Large traders file promptly, update annually and give their identification number to their broker-dealers. Form 13H information is kept confidential and treated as exempt from Freedom of Information Act disclosure, subject to limited exceptions. A family office trading at scale is visible to the regulator, not to the market.

Form PF: does not apply

Form PF is the confidential private-fund risk report filed by SEC-registered advisers that, with related persons, manage at least $150 million in private fund assets. A family office relying on the exclusion is not an investment adviser, so Form PF does not reach it, however large or leveraged its book. The leverage and counterparty data the SEC collects confidentially from registered hedge fund advisers is not collected from family offices.

Form SHO: short positions, deferred to 2028

Rule 13f-2 and Form SHO, adopted in October 2023, apply to institutional investment managers as defined in Section 13(f)(6)(A), which can include family offices. Managers would report monthly, within 14 calendar days of month end, gross short positions in a reporting company's equity averaging $10 million or more, or 2.5% or more of shares outstanding, with a $500,000 test for non-reporting issuers. The SEC would publish only aggregated data by security. After the Fifth Circuit remanded the rule for further economic analysis, an SEC order of December 3, 2025 extended the compliance date to January 2, 2028, with first filings due February 14, 2028.

Security-based swaps: one rule adopted, one withdrawn

Archegos prompted direct rulemaking on swaps, and the outcome is often misstated.

• Proposed, December 15, 2021 (Release 34-93784; Press Release 2021-259): Rule 9j-1 (fraud and manipulation in security-based swaps), Rule 15fh-4(c) (undue influence over swap dealers' chief compliance officers) and Rule 10B-1, which would have required anyone with a security-based swap position above set thresholds to file promptly and publicly on a new Schedule 10B. Then-Chair Gary Gensler cited the Archegos collapse and its use of total return swaps.
• Adopted, June 7, 2023 (Release 34-97656): Rules 9j-1 and 15fh-4(c), effective August 29, 2023. Rule 10B-1 was not adopted, and its comment period was reopened on June 20, 2023 (Press Release 2023-113).
• Withdrawn, June 12, 2025 (Releases 33-11377 and 34-103247): the SEC formally withdrew proposed Rule 10B-1 with 13 other pending proposals, effective on Federal Register publication on June 17, 2025. It said it does not intend to finalize them and that any future action would require a new proposal.

As of October 2026, the United States has no public, position-level reporting of large security-based swap positions. Rule 9j-1 is an antifraud tool for after the fact. It does not make positions visible in advance.

State-level rules

As noted, states cannot require a qualifying family office to register as an adviser but keep antifraud authority. Entity-level ownership regimes produce no public investment data. FinCEN's interim final rule of March 26, 2025 exempted U.S.-formed entities from Corporate Transparency Act beneficial ownership reporting, and a final rule announced August 11, 2026 and effective August 14, 2026 made that exemption permanent; foreign reporting companies still report their non-U.S. beneficial owners. New York's LLC Transparency Act took effect January 1, 2026. Because it uses the federal definitions, it now reaches only LLCs formed under foreign law and authorized to do business in New York, after Governor Hochul vetoed decoupling amendments on December 19, 2025.

Obligation vs threshold vs applies to family offices?

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Part III: Archegos Capital Management

The facts below come from the SEC's civil complaint (SEC v. Hwang et al., S.D.N.Y., filed April 27, 2022), the SEC's press release, the Federal Reserve's 2023 enforcement action, and reporting on the parallel criminal case brought by the U.S. Attorney's Office for the Southern District of New York (United States v. Hwang, No. 1:22-cr-00240). Complaint allegations are the SEC's allegations and have not been adjudicated in the civil case. The criminal verdict and sentences are a matter of record.

A family office built from a hedge fund

In December 2012 the SEC announced a $44 million settlement of insider trading and attempted manipulation charges against Sung Kook (Bill) Hwang and his hedge fund firms Tiger Asia Management and Tiger Asia Partners. The U.S. Attorney's Office in New Jersey filed criminal charges against Tiger Asia Management. According to the SEC's 2022 complaint, Hwang pleaded guilty to insider trading charges on Tiger Asia's behalf, returned investor capital, and converted Tiger Asia into Archegos by approximately 2013.

The complaint describes Archegos Capital Management, LP as "a family office headquartered in New York, NY exempt from registration as an investment adviser under Rule 202(a)(11)(G)-1." It invested Hwang's personal funds, and Hwang made every investment decision. The exclusion turns on who the clients are, not on the principal's history or the risk the office takes.

Synthetic, concentrated, spread across banks

The complaint alleges:

• Leverage typically between 400% and 700%, sometimes as high as 1,000%.
• Concentration in about 100 issuers, with a third to half of gross exposure typically in the 10 largest positions.
• Deliberately synthetic exposure. "The vast majority of Archegos's long exposure was synthetic, a deliberate strategy Hwang implemented to limit the visibility of market participants and Counterparties into the extent of Archegos's aggregate holdings."
• Managing around 5%. As cash equity holdings approached 5% of an issuer's shares, Archegos generally switched to swaps. Its chief risk officer circulated a daily report tracking cash positions against shares outstanding so Archegos never exceeded the 5% beneficial ownership threshold.
• About a dozen counterparties, mostly for single-name total return swaps with two-year terms, hedged by the banks' delta-one desks buying the reference shares. Each bank could see its own positions but had limited or no visibility into the others.

Because the banks bought the hedge shares, the shares backing Archegos's swaps sat on the banks' books. In GSX, according to the complaint, the disclosed holders were principally banks and other financial institutions, the institutions that would hold such hedges.

How large it became

Per the complaint, Archegos had about $1.6 billion of invested capital on about $10.2 billion of gross exposure as of March 31, 2020, and over $36 billion on over $160 billion as of March 22, 2021. By late March 2021, based on its own estimates, its combined cash and swap exposure equated to over 70% of the outstanding shares of GSX Techedu, over 60% of Discovery Class A, over 50% of iQIYI and of ViacomCBS, over 45% of Tencent Music Entertainment and over 30% of Discovery Class C.

None of this appeared in public ownership filings. A news report published by the Boston Globe in April 2021 said Archegos did not appear to have ever filed a 13F or a 13D. A search of EDGAR's company index for "Archegos" returns no filer under that name.

The representations

The fraud case centered on what Archegos told counterparties about what they could not see:

• Concentration. Staff allegedly told counterparties the largest position was about 35% of capital when the largest, ViacomCBS, was at one point over 60%.
• "Not a disclosed holder." In February 2021, a counterparty employee asked about GSX exposure across all banks. The head trader first replied that Archegos was not a "disclosed holder," meaning it had made no Section 13(d) filings. The employee pointed out that the disclosed holders were mainly banks, the institutions that would hold hedge shares for swaps. Archegos's GSX exposure was then about 59% of outstanding shares, and the counterparty extended more capacity after misleading assurances.
• Signed 13(d) representations. One counterparty's swap confirmations required Archegos to represent that its Section 13(d) beneficial ownership, plus the notional shares under its long derivatives, was below 5% of outstanding shares. The complaint alleges the chief financial officer signed confirmations when that was false.

The collapse, March 22 to 26, 2021

After the close on March 22, ViacomCBS announced a $3 billion secondary offering. On March 23, Archegos added about $2.6 billion of positions, mostly swaps in its concentrated names, as capital fell from $36.2 billion to $32.7 billion. On March 24, the offering priced at $85 against a prior close of $100.34, and China-based ADRs fell. Archegos asked a counterparty to return excess margin, its risk officer allegedly saying it still had $9 billion in cash, and received $248 million. By the close, capital was $16.9 billion, a one-day loss of 48%, and Archegos told banks it could not meet about $10.7 billion of margin calls. On March 25, capital fell to $9.2 billion. Talks with the largest counterparties failed over the weekend, and the banks delivered default notices and unwound the positions.

Losses, convictions and response

Bank losses. Trial coverage put losses at more than $10 billion across banks, including about $5.5 billion at Credit Suisse and about $2.9 billion at Nomura. On July 24, 2023, the Federal Reserve fined UBS Group AG, Credit Suisse's acquirer, $268.5 million for unsafe and unsound counterparty credit risk management with Archegos, acting alongside the Bank of England's Prudential Regulation Authority and Swiss FINMA. The Fed and PRA penalties totaled about $387 million.

Charges and verdict. On April 27, 2022, the SEC charged Hwang, Archegos, chief financial officer Patrick Halligan, head trader William Tomita and chief risk officer Scott Becker with securities fraud and, as to Hwang, Tomita and Archegos, market manipulation (Press Release 2022-70); the same day, federal prosecutors in Manhattan brought a parallel criminal case against Hwang and Halligan. On July 10, 2024, a Manhattan federal jury convicted Hwang on 10 of the 11 counts he faced, including racketeering conspiracy, securities fraud, wire fraud and market manipulation, and acquitted him on one market manipulation count. Halligan was convicted on all three counts he faced: racketeering conspiracy, securities fraud and wire fraud.

Sentences and appeals. On November 20, 2024, U.S. District Judge Alvin Hellerstein sentenced Hwang to 18 years in prison; prosecutors had sought 21. On January 27, 2025, the same judge sentenced Halligan to eight years. Both appealed to the U.S. Court of Appeals for the Second Circuit. Reporting in early 2026 described Hwang as free on bail pending appeal, and as of October 9, 2026 we found no appellate decision on either appeal; the convictions stand unless the appeals court rules otherwise.

Legislation. On July 22, 2021, Representative Alexandria Ocasio-Cortez introduced the Family Office Regulation Act of 2021 (H.R. 4620), which would have limited the exclusion to offices with less than $750 million in assets under management. The House Financial Services Committee ordered it reported in amended form by a 27-22 vote on July 29, 2021. That was its last recorded action, and it was not enacted before the 117th Congress ended.

What Archegos does and does not show

Archegos is often summarized as a "family office loophole." The record is narrower. The exclusion mattered at the edges. With no Form ADV or Form PF, regulators had no routine confidential view of Archegos's leverage and counterparty concentration, the kind of data Form PF collects from registered hedge fund advisers. H.R. 4620 targeted that gap.

The public disclosure gap came from the swaps. The 5% and 10% thresholds, Form 13F and Form 13H applied to Archegos as they apply to anyone. A June 2021 Katten analysis noted that total return swaps are exempt from many reporting requirements whether the holder is an exempt family office or a registered adviser. By the complaint's account, Archegos treated the 5% line as binding, tracking it daily and moving to swaps as it approached. The SEC's case alleged misstatements to counterparties and manipulative trading; it did not charge a failure to file.

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Part IV: What This Means for Counterparties

The following describes how the disclosure framework shapes what a prime broker or swap dealer can learn about a family office client. It is not a recommendation.

Public filings show the floor. A family office's 13F, 13D/G and Section 16 filings show direct listed holdings, subject to confidential treatment. They show nothing about swap exposure, which for a leveraged client can be most of the book. The GSX exchange shows that "not a disclosed holder" can describe the largest economic holder in a name.

No one aggregates across dealers for you. With no Form PF for family offices and Rule 10B-1 withdrawn, no filing combines a family office's swap exposure across dealers in a form any single counterparty can see. Aggregate exposure still has to come from the client.

Representations carry the risk. The confirmations in the complaint show dealers trying to close the gap contractually, with the client attesting that beneficial ownership plus derivative notional stayed below 5%. Such representations depend on the client's honesty, but they define what is being attested and create a record. Alongside its manipulation claims, the SEC's case rested in large part on alleged false statements about concentration, liquidity and cash.

Public data offers partial cross-checks. A client's stated concentration can be set against its 13F, and banks appearing as large holders of a reference name may be holding hedges for someone's swaps, as the GSX exchange in the complaint illustrates.

Faster 13D deadlines and the synthetic route. With five business days to file at 5%, the pattern described in the complaint, cash holdings kept below 5% and large swap exposure above it, remains outside public ownership filings.

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Part V: The Intelligence Implication

For a fund distribution team, an RIA seeking co-investors or a researcher mapping family-office activity, the disclosure map sets the limits of what can be known.

The absence of Form ADV is a signal. Registered advisers, including multi-family offices that give investment advice, report assets, clients, private funds and ownership on Form ADV. A single family office relying on the exclusion files none of it. Identifying single family offices therefore works from the other direction: entities that appear in Exchange Act filings and other public documents without an adviser registration. Our family office directory is built on that distinction, and our data methodology explains how firms are classified.

13F is the main window, with gaps. Above $100 million in Section 13(f) securities, 13F gives a quarterly, 45-day-lagged view of listed long positions. It leaves out derivatives, private assets and shorts, and can omit positions under confidential treatment. A small 13F portfolio may reflect what an office holds in listed form, not its total allocation.

Ownership filings are faster. Schedules 13D and passive 13G within five business days, and Section 16 reports within two, are the most timely public evidence of large positions. For 10% holders, Section 16 is the clearest public record of security-based swap transactions.

Some regimes are invisible by design. Form 13H is confidential. Form SHO will publish only aggregates, and not before 2028. Public swap-position reporting was withdrawn. Anyone claiming to see a family office's full derivatives exposure from public data is overstating what exists.

Adjacent filings fill in structure. Many families run private foundations alongside their offices. Form 990-PF returns and their attachments are subject to public disclosure under Internal Revenue Code Section 6104 and can show holdings and managers. Since 2020, qualifying family offices can invest in private offerings as accredited investors in their own right. Resolving these sources, 13F and ownership filings to the same family is what turns scattered documents into a profile. The registered side of the market is covered in our RIA directory.

Archegos marks where public data stops. Before March 2021, its public record contained almost nothing: no Form ADV, and no 13D or 13F that contemporaneous reporting could find. According to the complaint, at least one counterparty employee read the indirect evidence, banks as the main disclosed holders of GSX, as a possible sign of large swap positions. Public-data analysis of family offices is valuable for coverage, relationships and listed positioning. It cannot measure leverage, and it should not be presented as if it could.

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Key sources

• U.S. Securities and Exchange Commission, Rule 202(a)(11)(G)-1, 17 CFR 275.202(a)(11)(G)-1; Release IA-3220 and Press Release 2011-134 (2011)
• Investment Advisers Act of 1940, Sections 202(a)(11)(G) and 203A(b), 15 U.S.C. 80b-2 and 80b-3a
• Securities Exchange Act of 1934, Sections 13(d), 13(f), 13(h), 13(o) and 16(a), 15 U.S.C. 78m and 78p
• SEC, Rules 13d-1, 13f-2 and 13h-1, 17 CFR 240.13d-1, 240.13f-2, 240.13h-1
• SEC, Modernization of Beneficial Ownership Reporting, Release 33-11253, Press Release 2023-219 and Fact Sheet (2023)
• SEC Division of Investment Management, Frequently Asked Questions About Form 13F (2026)
• SEC, Release 34-93784 and Press Release 2021-259 (2021); Release 34-97656 and Press Release 2023-113 (2023)
• SEC, Withdrawal of Proposed Regulatory Actions, Release 33-11377 / 34-103247, Federal Register document 2025-11110 (2025)
• SEC, Press Release 2020-191 and Rule 501(a), 17 CFR 230.501 (2020); Private Investor Coalition, Petition for Rulemaking 4-899 (2026)
• SEC v. Sung Kook (Bill) Hwang et al., Complaint, Case 1:22-cv-03402 (S.D.N.Y. 2022); SEC Press Release 2022-70 (2022); SEC Press Release 2012-264 (2012)
• Board of Governors of the Federal Reserve System, enforcement action against UBS Group AG (July 24, 2023)
• U.S. Congress, H.R. 4620, Family Office Regulation Act of 2021 (117th Congress)
• United States v. Hwang et al., No. 1:22-cr-00240 (S.D.N.Y.); appeals to the U.S. Court of Appeals for the Second Circuit (pending as of October 2026)
• NBC News, Al Jazeera, Boston Globe, Reuters/Yahoo Finance and Bloomberg reporting (2021, 2024, 2025, 2026)
• Seward & Kissel and Morgan Lewis on Form SHO (2025); Bass, Berry & Sims on the FinCEN interim final rule (2025); U.S. Treasury, FinCEN final rule on beneficial ownership reporting (August 2026); Capitol Services on the New York LLC Transparency Act (2026); Katten, Family Offices Receive Increased Regulatory Scrutiny (2021)
• Internal Revenue Service, Instructions for Form 990-PF (2025)

Wealthmetrica provides intelligence on investment advisers, family offices and the people who run them. This analysis draws on public regulatory filings, statutes and published research; it is not legal, tax, or investment advice.