Stephen Keen

Stephen Keen

Reed Smith

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Fair Valuation and Mutual Fund Directors: New Guidance from the SEC

1. Previous Guidance Codified by the Release - Much of the guidance included in the Release is already in section 404 of the CFRP. In fact, the amount of repetition in the revised section may confuse a first-time...more

9/2/2014 - Mutual Funds SEC Securities Valuation

Fair Valuation and Mutual Fund Directors: The Great Valuation Divide and Its Implications

The 1940 Act’s requirements for valuing portfolio securities may be summarized as follows: the board of directors must determine, in good faith, the fair value of every portfolio security for which a market quotation is not...more

7/21/2014 - Board of Directors Investment Advisers Act of 1940 Mutual Funds SEC Valuation

Fair Valuation and Mutual Fund Directors: Alternative Approaches to Valuation

Directors’ legal responsibilities for valuing portfolio securities is a logical place to start an examination of why misvalued securities pose a risk to independent directors. This Client Alert therefore considers the...more

6/16/2014 - Compliance Directors Enforcement Enforcement Actions Fair Valuation Investment Company Act of 1940 Mutual Funds SEC Valuation

Fair Valuation and Mutual Fund Directors: History of Enforcement Actions Against Independent Directors

At the ICI 2014 Mutual Funds and Investment Management Conference, the staff of the Division of Investment Management announced that it would not propose comprehensive guidance on valuation of investment company portfolios...more

6/6/2014

Systemic Risk and Asset Management: Progressing from Ignorance to Confusion

Early this year, the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) issued a Consultative Document regarding Assessment Methodologies for Identifying Non-Bank Non-Insurer...more

2/24/2014 - Banks FSB IOSCO Nonbank Firms SIFIs

Money Market Fund Reform: The Next Crossroads

The period for comments on the Securities and Exchange Commission’s proposed money market fund reforms ended September 17. The tone of the comment letters, as well as the large quantity of responses, should serve to remind...more

10/15/2013 - FSOC Investors Money Market Funds SEC

Observations on the SEC’s Latest Approach to Money Market Reform

On June 5, 2013, the Securities and Exchange Commission ("Commission") unanimously voted to propose rules that would alter the way that money market funds operate. Shortly thereafter, the Commission released the proposed...more

6/7/2013 - Asset Diversification Disclosure Requirements Liquidity Fees Money Market Funds NAV Redemption Gates SEC Stress Tests

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