Kelley A. Howes

Kelley A. Howes

Morrison & Foerster LLP

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Investment Management Legal + Regulatory Update -- September 2014

In This Issue: - Regulation: Long-Awaited Money Market Fund Rules Adopted - SEC Staff Offers Guidance Regarding Investment Advisers and Proxy Advisory Firms - SEC Staff Closes Loophole on BDC Asset...more

9/17/2014 - Banks CFTC Conflicts of Interest CPO Dodd-Frank Enforcement Actions FINRA Hedge Funds Investment Adviser Liquidity Fees Money Market Funds Municipal Advisers NAV Pay-To-Play Proxy Advisors Redemption Gates SEC Strategic Enforcement Plan Whistleblowers

NFA Requests Comments on Need for CPO/CTA Capital Requirements

Should the National Futures Association (NFA) impose capital requirements on commodity pool operators (CPOs) and commodity trading advisors (CTAs)? On January 23, 2014, the NFA published a Notice to members seeking public...more

2/12/2014 - CFTC CPO CTA NFA

Year-End CFTC Reporting Requirements for Fund Advisers

The National Futures Association (NFA) reminded fund advisers claiming an exemption from registering as a commodity pool operator (CPO) that they must confirm by March 3, 2014 that will continue to rely on the exemption....more

12/12/2013 - CFTC CPO Exemptions Investment Adviser NFA Reporting Requirements Year-End Planning

Investment Management Legal + Regulatory Update -- October 2013

- Regulatory Updates: CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that are Commodity Pools; SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Investment...more

10/24/2013 - Audits Bad Actors Broker-Dealer CFTC Commodity Pool Compliance Continuity of Enterprises Dodd-Frank Enforcement FINRA General Solicitation Investment Adviser JOBS Act PCAOB Private Funds Rule 506 Offerings SEC

CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that Are Commodity Pools

In a dramatic change of course, the Commodity Futures Trading Commission (CFTC) adopted final rules that apply a “substituted compliance” approach for disclosure and compliance obligations of registered investment companies...more

8/15/2013 - CFTC Commodity Pool Compliance Disclosure Requirements Investment Funds Reporting Requirements SEC

Investment Management Legal + Regulatory Update -- July 2013

In This Issue: Regulatory Updates - SEC Proposes Money Market Reform; SEC Eases Ban on General Solicitation and General Advertising in Certain Private Placements; SEC and CFTC Adopt Joint Rules to Address...more

7/19/2013 - Broker-Dealer CFTC Disclosure Requirements FSOC General Solicitation Identity Theft Insider Trading Investment Funds JOBS Act Marketing Money Laundering Money Market Funds New Legislation New Regulations Nonbank Firms NYSE Private Placements SEC Social Media Tax Reform Whistleblowers

Investment Management Legal + Regulatory Update -- December 2012

In This Issue: Regulatory Updates - FSOC, FSB Turn Up Heat on SEC on Money Market Fund Reforms; SEC Staff: Beware of BDC Joint Transactions; SEC Reports 3,000 Whistles Blown in FYI 2012; Over 1500 Private Fund Advisers...more

12/18/2012 - CFTC CPO FSB FSOC FX Forwards FX Swaps Money Market Funds SEC

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