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 Registered with SEC since Enactment of Dodd-Frank; SEC Confirms Status of Investment Adviser Solely to Foreign Insurance Companies; CFTC Issues Fund of Funds Relief from CPO Registration; CFTC Clarifies How CPO Exemption Applies to BDC Operators; US Treasury Excludes FX Swaps and Forwards From Dodd-Frank Swaps Rules; Rule 4.5 and Rule 4.13(a)(3) CPO Exemption Notice Filing Deadline – December 31, 2012

Enforcement + Litigation - Hedge Fund Advisory Firm Charged in Largest Insider Trading Scheme Ever Charged; SEC Charges Purported Investment Adviser with Fraud for Spending Investor Funds on Drugs, Gambling, Cigars and Travel; SEC Sanctions Investment Advisory Firms for Impeding Investigations, One Inflating AUM in Order to Register with the SEC; SEC Fines Adviser for Deficient Variable Annuity Disclosures; Federal Jury Acquits Prime Reserve Fund Managers of Fraud Charges; SEC Sanctions BDC and its Principal Officers for Fair Valuation Errors; and Federal Court Tosses ICI Challenge to Rule 4.5.

Please see full issue below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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