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
The U.S. Securities and Exchange Commission on April 21, 2020 proposed a long-anticipated framework for fair valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish...more
5/26/2020
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Fair Value Standard ,
Fund Managers ,
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Investment Adviser ,
Investment Company Act of 1940 ,
No-Action Letters ,
Proposed Rules ,
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Securities and Exchange Commission (SEC) ,
Valuation
On April 21, 2020, the U.S. Securities and Exchange Commission proposed a long-anticipated framework for valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish requirements...more
4/26/2020
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Valuation
The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more
1/11/2020
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Business Development Companies ,
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Registered Investment Companies (RICs) ,
Reporting Requirements ,
Repurchase Agreements ,
Rule 18f-4 ,
Securities and Exchange Commission (SEC) ,
Swaps
The U.S. Court of Appeals for the Second Circuit, in disagreeing with the Courts of Appeals for the Third and Ninth Circuits, ruled on August 5, 2019 in Oxford University Bank v. Lansuppe Feeder, Inc. that a private right of...more
9/10/2019
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Breach of Contract ,
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Liquidation ,
Mutual Funds ,
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Private Right of Action ,
Rescission ,
Section 47(b) ,
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Summary Judgment ,
Trusts
In a letter to U.S. Securities and Exchange Commission (SEC) Chairman Jay Clayton, the Investment Company Institute (ICI) formally requested a delay and re-examination of certain elements of Rule 22e-4 under the Investment...more
8/18/2017
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Filing Deadlines ,
Form N-CEN ,
Form N-PORT ,
Investment Company Act of 1940 ,
Investment Portfolios ,
Liquidity Risk Management Rule ,
Reporting Modernization Rules ,
Reporting Requirements ,
Request for Examination ,
Securities and Exchange Commission (SEC)
When the SEC adopted Rules 38a-1 under the Investment Company Act of 1940 (Investment Company Act) and 206(4)-7 under the Investment Advisers Act of 1940 (Advisers Act) in 2003 – which required registered funds and registered...more
10/13/2015
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Testimonial Statements
So you are an investment adviser registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (“Advisers Act”). You currently manage separate accounts and, perhaps, one...more