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Richard F. Morris

Richard F. Morris

Morgan Lewis


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SEC Settles Suit for Misleading Advisory Contract Approval Disclosure

Settlement with mutual fund directors and service providers serves as a reminder of responsibilities for disclosures relating to the approval of investment advisory contracts and provides insight into SEC enforcement...more

5/10/2013 - Advisory Contracts Disclosure Requirements Investment Adviser Investment Company Act of 1940 Mutual Funds SEC Settlement

FINRA Formalizes Position on Pre-Inception Index Performance Data

Interpretive letter outlines the conditions for the use of exchange-traded product marketing materials containing pre-inception index performance, including disclosure requirements, performance presentation standards, and a...more

4/26/2013 - Compliance Disclosure Requirements Exchange-Traded Products FINRA Institutional Investment

Sale of U.S. ETFs in Latin America

U.S. sponsors should be aware of local restrictions before offering shares. Exchange traded funds (ETFs) and similar vehicles organized in the United States have become increasingly popular investment choices for Latin...more

3/7/2013 - ETFs Foreign Investment

Select SEC and FINRA Cases and Developments: 2012 Year in Review

In 2012, the SEC and FINRA continued their vigorous enforcement of the securities laws, rules, and regulations—with cases against broker-dealers, investment advisers, and investment companies accounting for 38% of the SEC...more

2/7/2013 - Broker-Dealer Enforcement Actions FINRA Investment Adviser SEC

SEC to Consider Exemptive Requests for Certain Actively Managed ETFs

Division of Investment Management to lift the moratorium on exemptive requests for actively managed ETFs investing in derivatives; new chapter signaled in the development of ETF industry. On December 6, Norm Champ, the...more

12/10/2012 - Derivatives ETFs SEC

Compilation of SEC Staff Guidance on Securities Lending

Division of Investment Management's guidance on securities lending by open-end and closed-end investment companies provides a reminder of legal obligations in lending programs. ...more

11/27/2012 - SEC

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