Kelley A. Howes

Kelley A. Howes

Morrison & Foerster LLP

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SEC Adopts Further Revisions to Rule 2a-7

The SEC recently adopted rule amendments removing credit rating references in Rule 2a-7 and Form N-MFP. Issuer diversification provisions were also amended to eliminate a current exclusion for securities subject to a...more

9/25/2015 - Amended Regulation Asset Diversification Board of Directors Credit Ratings Duty to Monitor Guarantors Money Market Funds New Guidance NRSRO Risk Assessment SEC

SEC Steps into Fund Boardroom Once Again; Charges Adviser with Misleading Board

The SEC charged a registered investment adviser and its principal with misleading a mutual fund’s board about the adviser’s portfolio management trading capabilities. The SEC said the adviser misled the board at two meetings...more

8/23/2013 - Board of Directors Funding Investment Advisers Act of 1940 Misleading Statements SEC

SEC Accuses Fund Directors of Breaching Their Valuation Duties

In a case involving fair valuation of structured notes, the SEC signaled that when investment company fund boards delegate the responsibility to fair value portfolio securities, they must provide “meaningful substantive...more

1/4/2013 - Board of Directors Enforcement Fiduciary Duty Investment Adviser SEC Valuation

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