Stephen Cohen

Stephen Cohen

Dechert LLP

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SEC Adopts Rules and Forms to Modernize Reporting Requirements for Registered Investment Companies

The U.S. Securities and Exchange Commission (SEC or Commission) has adopted, by a 2-to-1 vote, new rules and forms, as well as amendments to certain rules and forms (Final Rule), to modernize the reporting of information by...more

11/9/2016 - Amended Forms Final Rules Form N-Cen Form N-PORT Investor Protection Registered Investment Companies (RICs) Regulation S-X Reporting Requirements SEC

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

10/14/2016 - Amended Regulation Disclosure Requirements Form N-PORT Investment Companies Investment Management Liquidity Risk Management Rule New Regulations Registered Investment Companies (RICs) Reporting Requirements SEC Swing Pricing

CFTC Guidance on FCM and DCO Investments in Money Market Funds

Divisions of the U.S. Commodity Futures Trading Commission (CFTC) on August 8, 2016 issued letters restricting futures commission merchants (FCMs) and derivatives clearing organizations (DCOs) from investing in money market...more

9/15/2016 - CFTC Commodities Exchange Act Derivatives Clearing Organizations DSIO FCMs Investment Investment Company Act of 1940 Money Market Funds No-Action Letters Rule 2a-7 SEC Stock Redemption

SEC IM Staff Issues Guidance Update on Disclosure Related to Current Market Conditions

The staff of the U.S. Securities and Exchange Commission Division of Investment Management (Staff) has issued an IM Guidance Update on fund disclosure regarding risks related to current market conditions (Guidance Update)....more

3/30/2016 - Debt Securities Disclosure Requirements Fixed Income Investments Investment Management Market Conditions Puerto Rico Risk Assessment SEC

U.S. Money Market Fund Reform: Diversification, Stress Testing and Disclosure Compliance Deadline Quickly Approaching; SEC Staff...

The April 14, 2016 compliance date for certain new money market fund (money funds) requirements adopted by the U.S. Securities and Exchange Commission (SEC) is quickly approaching. In particular, money funds will be required...more

2/17/2016 - Asset Diversification Investment Company Act of 1940 Money Market Funds SEC Stress Tests

Financial Services Quarterly Report - Fourth Quarter 2015: Is the U.S. SEC IM Guidance Update Initiative Becoming a Thing of the...

Over the past three years, the Division of Investment Management (Division) of the U.S. Securities and Exchange Commission (Commission) has provided informal guidance and interpretations regarding issues of relevance to the...more

12/28/2015 - Cybersecurity Division of Investment Management Escheat Guidance Update Investment Management Meals-Gifts-and Entertainment Rules Registered Investment Advisors SEC

SEC Amends Rule 2a-7 to Eliminate References to NRSRO Ratings and to Revise Issuer Diversification Requirements

The U.S. Securities and Exchange Commission (SEC) recently adopted amendments (Amendments) to remove references to credit ratings in Rule 2a-7 under the Investment Company Act of 1940, as amended (1940 Act), the primary rule...more

11/10/2015 - ABS Asset Diversification Bonds Diversification Requirements Dodd-Frank Investment Company Act of 1940 Money Market Funds Municipal Securities Issuers NRSRO Repurchases Rule 2a-7 SEC

SEC Proposes to Amend Form ADV and Investment Adviser Recordkeeping Rules

The U.S. Securities and Exchange Commission (SEC or Commission) recently proposed amendments to Form ADV and to Rule 204-2 (Recordkeeping Rule) and other rules under the Investment Advisers Act of 1940, as amended (Advisers...more

7/17/2015 - CCO Disclosure Requirements Dodd-Frank Form ADV Investment Adviser Investment Advisers Act of 1940 RAUM Recordkeeping Requirements Risk Assessment SEC Social Media Umbrella Registration

SEC Staff Issues Money Market Fund Reform Frequently Asked Questions

The Staff of the Division of Investment Management (Staff) of the U.S. Securities and Exchange Commission (SEC or Commission) has published responses to frequently asked questions (FAQs) regarding the SEC’s 2014 amendments...more

6/17/2015 - Amortization Capital Contributions Disclosure Requirements Division of Investment Management Floating NAV Fund Managers Investment Companies Liquidity Fees Money Market Funds NAV New Amendments Redemption Gates Reorganizations SEC Securities Act of 1933 Seed Financing Websites

U.S. Money Market Fund Reform: Form N-CR and Related Website Disclosure Compliance Deadline Quickly Approaching

The July 14, 2015 compliance date for certain new money market fund reporting and disclosure requirements adopted by the U.S. Securities and Exchange Commission (SEC) is quickly approaching. In particular, money market funds...more

5/22/2015 - Compliance Disclosure Requirements EDGAR Investment Adviser Investment Funds Money Market Funds NAV SEC

U.S. SEC Approves Proposals to Modernize Reporting Requirements for Registered Investment Companies and Registered Investment...

The U.S. Securities and Exchange Commission (SEC) today unanimously approved proposals (Proposals) to modernize the reporting of information provided by registered investment companies (funds) and registered investment...more

5/22/2015 - Annual Reports Financial Statements Form ADV Form N-Cen Form N-PORT Form N-SAR Form PF Investment Adviser Investment Companies Private Funds Public Disclosure Regulation S-X Reporting Requirements SEC

The U.S. Securities and Exchange Commission Approves Amendments to Rules Governing Money Market Funds: Implications for Boards

The U.S. Securities and Exchange Commission (SEC) has approved sweeping amendments to Rule 2a-7 under the Investment Company Act of 1940 and other rules governing the operations of money market funds (money funds)...more

10/15/2014 - Disclosure Requirements Floating NAV Investment Company Act of 1940 Liquidity Fees Money Market Funds New Amendments Redemption Gates SEC Stress Tests

Money Market Funds - Focus Shifts to Europe

Following the adoption by the U.S. Securities and Exchange Commission (“SEC”) of amendments to the rules governing U.S. money market funds (“MMFs”), the focus is shifting to Europe. In fact, the prospects for sensible MMF...more

10/14/2014 - EU European Commission Floating NAV Liquidity Fees Money Market Funds Redemption Gates SEC

U.S. SEC Approves Sweeping Amendments to Rules Governing Money Market Funds

The U.S. Securities and Exchange Commission (SEC or Commission) on July 23, 2014 approved, by a vote of 3- 2, sweeping amendments to Rule 2a - 7 and other rules that govern money market funds (money funds) under the...more

8/14/2014 - Investment Company Act of 1940 Money Market Funds NAV SEC

SEC Approves Amendments to Rules Governing Money Market Funds

Yesterday, the U.S. Securities and Exchange Commission (“SEC”), by a vote of 3 to 2, approved amendments to Rule 2a-7 and other rules that govern money market funds under the Investment Company Act of 1940 (the “Amendments”)....more

7/24/2014 - Liquidity Fees Mary Jo White Money Market Funds NAV New Amendments Redemption Gates SEC

The U.S. Supreme Court Extends Sarbanes-Oxley Whistleblower Protections to Employees of Mutual Fund Investment Advisers and Other...

The Supreme Court of the United States on March 4, 2014 held that employees of a privately-held mutual fund investment adviser are protected under a whistleblower provision enacted as part of the Sarbanes-Oxley Act of 2002...more

3/27/2014 - Contractors FMR LLC Lawson v FMR Sarbanes-Oxley SCOTUS Subcontractors Whistleblower Protection Policies Whistleblowers

SEC’s Division of Investment Management Issues Recommendations for Funds and Fund Advisers in Light of Reduced Market-Making...

The Division of Investment Management (“Division”) of the U.S. Securities and Exchange Commission (“SEC”) recently published guidance (“Guidance”) addressing steps that funds and fund advisers should consider in light of...more

2/14/2014 - Banking Sector Broker-Dealer Federal Reserve Fixed Income Investments Internal Revenue Code (IRC) Investment Adviser Investment Funds Investment Management Market Making Market Risk Capital Rule SEC Volcker Rule

SEC Charges an Investment Adviser and a Portfolio Manager with Fraud and Causing a Money Market Fund to Violate Rule 2a-7

This OnPoint describes the role of the SEC’s Division of Investment Management (Division) in uncovering the alleged fraud through an analytical review of the Fund’s performance data and portfolio information. It then...more

12/19/2013 - Enforcement Enforcement Actions Fraud Fund Managers Investment Fraud Investor Protection OCIE Portfolio Managers Risk Assessment Risk Management SEC Securities Fraud

Financial Services Quarterly Report - Third Quarter 2013: U.S. SEC’s Proposal to Amend Rules Governing Money Market Funds:...

The U.S. Securities and Exchange Commission (“SEC”) has proposed sweeping amendments to Rule 2a-7 under the Investment Company Act of 1940 (“1940 Act”) and other rules relating to money market funds (“money funds”).1 The...more

10/10/2013 - Disclosure Requirements Investment Company Act of 1940 Liquidity Fees Money Market Funds NAV Redemption Gates SEC Stress Tests

IRS Proposes De Minimis Exception to Wash Sale Rules in Connection with SEC Money Market Fund Floating NAV Proposal

The U.S. Internal Revenue Service (IRS) has proposed a new Revenue Procedure (Proposed Revenue Procedure) regarding the application of the wash sale rules under Section 1091 of the U.S. Internal Revenue Code (Code) to...more

8/1/2013 - Investment Company Act of 1940 IRS Money Market Funds NAV SEC Wash Sale Rules

SEC Proposes Sweeping Amendments to Rules Governing Money Market Funds

The U.S. Securities and Exchange Commission (SEC or Commission) on June 5, 2013 proposed for public comment sweeping amendments to Rule 2a-7 under the Investment Company Act of 1940 and other rules relating to money market...more

6/19/2013 - Amended Regulation Asset Diversification Disclosure Requirements Exemptions Fees FSOC Investment Company Act of 1940 Money Market Funds Redemption Gates SEC

SEC Proposes Amendments to Rules Governing Money Market Funds

On June 5, 2013, the U.S. Securities and Exchange Commission (SEC) unanimously proposed for public comment two alternatives for amending Rule 2a-7 and other rules that govern money market funds under the Investment Company...more

6/7/2013 - Great Recession Investment Company Act of 1940 Money Market Funds NAV SEC

The Debate Continues – U.S. Money Market Fund Update

Since the U.S. Financial Stability Oversight Council (“FSOC”) issued proposed recommendations to the U.S. Securities and Exchange Commission (“SEC”) regarding additional reforms to money market fund (“money fund”) regulation...more

3/5/2013 - FSOC Money Market Funds SEC

IOSCO and FSB Recommend Additional Money Market Fund Reform, Putting International Pressure on the SEC to Take Action

Introduction - The International Organization of Securities Commissions (IOSCO), an international organization of securities regulators, recently published its “Policy Recommendations for Money Market Funds” (Final...more

1/4/2013 - FSB International Finance IOSCO Money Market Funds SEC

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