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U.S. Treasury Implements Significant Changes to TIC SLT Form: Implications for Investment Managers

Effective for reports as of November 2022 (i.e., those reports due in December 2022) and afterwards, the U.S. Department of Treasury (Treasury) has implemented important and significant changes to the reporting requirements...more

SEC Issues Proposed Rule Amendments Regarding Fund Naming Conventions

Overview - The U.S. Securities and Exchange Commission, by a vote of three-to-one, proposed for public comment on May 25, 2022, amendments to the rule governing naming conventions of funds1 subject to the U.S. Investment...more

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers (UPDATED)

In March 2022, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of U.S. ownership of foreign securities....more

SEC Rulemaking: Good Faith Determinations of Fair Value Under the Investment Company Act

The U.S. Securities and Exchange Commission on December 3, 2020 adopted a long-anticipated rule for the fair valuation of fund investments. Rule 2a-5 under the Investment Company Act of 1940 (final rule or rule): defines...more

ERISA’s Social Goals? ESG Considerations Under ERISA

A substantial portion of available global investment capital is held under private U.S. pension and other employee benefit plans governed by the Employee Retirement Income Security Act of 1974 (“ERISA”). At the same time, for...more

U.S. Treasury’s Benchmark TIC SHL Survey and Implications for Investment Managers

In August 2019, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of foreign residents’ holdings of U.S. issuers’ securities. The information will...more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - January 2019

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

SEC Staff Extends Effectiveness of No-Action Relief on Auditor Independence and the “Loan Provision”

The U.S. Securities and Exchange Commission’s Division of Investment Management (SEC Staff) on September 22, 2017 extended indefinitely the effectiveness of no-action relief granted a year earlier with respect to the...more

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

TIC SHC is a mandatory benchmark study commissioned by the Treasury and administered by the FRBNY every five years.3 The survey reviews holdings of foreign portfolio securities – including short- and long-term securities and...more

SEC Adopts New Rules and Rule Amendments to: (1) Require Liquidity Risk Management Programs for Registered Open-End Investment...

Earlier today, the U.S. Securities and Exchange Commission (SEC) unanimously adopted a new rule and amendments to certain rules and forms that will require registered open-end investment companies, including mutual funds and...more

U.S. Treasury’s Benchmark TIC SHL Survey and Implications for Investment Managers

In August 2014, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of foreign holdings of U.S. issuers’ securities on Treasury International Capital...more

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