Investment Management Legal + Regulatory Update -- September 2014

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In This Issue:

- Regulation: Long-Awaited Money Market Fund Rules Adopted

- SEC Staff Offers Guidance Regarding Investment Advisers and Proxy Advisory Firms

- SEC Staff Closes Loophole on BDC Asset Coverage Requirements

- SEC Staff Warns Against “Disclosure Creep”

- SEC Staff: Measure Percentage Ownership by Fund, Not by Complex

- SEC Launches Exam Initiative for Newly Registered Municipal Advisers

- U.S. House Votes to Reauthorize the CFTC and Exclude Most RICs from CPO and CTA Requirements

- Banking Regulators: Exit Fees for Bond Mutual Funds?

- Commissioner Piwowar Slams “Dodd-Frank Politburo” for Overstepping Authority

- Spotlight on BDCs BDC Trend, or Too Early to Tell?

- Enforcement + Litigation: Paying for Playing: SEC Brings First Pay-to- Play Action Against an Investment Adviser

- Investment Advisory Firm and Its Owners Charged with Failing to Disclose Conflicts of Interest

- Lying to Examiners Can Lead Quickly to Criminal Charges

- Hedge Fund Manager Charged with Portfolio Pumping

- Something Old, Something New: SEC Brings Action for Prohibited Principal Transactions and Retaliation Against Whistleblower

- VA Switches: FINRA Disciplinary Action Reminds Firms About the Need for Adequate Supervisory Procedures

- Tidbits

- Excerpt from Regulation: Long-Awaited Money Market Fund Rules Adopted:

On July 28, 2014, a divided SEC adopted rules that will require floating net asset values (NAVs) for institutional money market funds and give most money market funds the discretion to impose liquidity fees and gates. The 3-2 vote, which closes the latest tumultuous chapter of money market fund regulatory reform, will fundamentally change the way that most money market funds operate.

Please see full publication 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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