Investment Management Update

In This Issue:

- SEC Announces First-of-Its-Kind Whistleblower Award To an Audit and Compliance Professional

- SEC Issues No-Action Letter To Allow for Amendment of a Sub-Advisory Agreement without Shareholder Approval

- SEC Works on Rules To Address Risks Posed by Asset Management Industry

- SEC Pay-To-Play Rules

- State Street Appeal Implicates the Supreme Court’s Janus Ruling

- SEC Scrutinizes Annual Advisory Agreement Renewal Process

- Final Municipal Advisor Registration Deadline Imminent

- Supreme Court Allows Anti-Retaliation Suits by Fund Service Providers’ Employees

- EU Court of Justice Ruling May Allow U.S. Funds To Obtain Tax Refunds

- SEC, Other Regulators Pursue Puerto Rico Bond Inquiries

- Investment Adviser Charged with Breaching Fiduciary Duties and Misleading Investors

- Proposed Changes to Taxation of Carried Interest

- SEC Fines One Adviser and Charges Another Defendant over Social Media Misuse, Issues Guidance on the “Testimonial Rule”

- Trend: Advisers Attacked for Overcharges on Subadvised Funds

- Following Janus Capital Group Holding, Second Circuit Declines To Find Rule 10b-5 Liability

- SEC’s Champ Outlines Investment Management Staff Priorities

- SEC Focuses Independent Fund Trustees on Audit Quality

- SEC’s Guidance on Unbundling of Proxy Proposals

- MSRB Proposes Municipal Advisory Supervision Rule, Proposes Amending Current MSRB Rules G-37 and G-3 to include Municipal Advisors, and Implements a New Fee for Municipal Advisors

- SEC Warns of Fixed Income Fund Risk

- PCAOB Evaluating Significant Changes to Auditor’s Report

- Champ Reviews Changes to Regulatory Landscape for Hedge Funds

- Mutual Fund Insider Trading Case Remanded

- Final Volcker Rule Adopted

- SEC Staff Issues Guidance Updates on S-X Rules 3-09 and 4-08(g) for Business Development Companies

- Excerpt from: SEC Announces First-of-Its-Kind Whistleblower Award To an Audit and Compliance Professional:

On August 29, 2014, the Securities and Exchange Commission (SEC) announced that it was rewarding an audit and compliance professional with a whistleblower award of more than $300,000 for reporting company wrongdoing to the SEC after the company failed to take action. This is the first whistleblower award granted to an employee who performs an audit and compliance function. The employee first reported the problem internally, but contacted the SEC when the company failed to take action within 120 days of the internal report. The information provided by the employee directly led to a successful SEC enforcement action against the company.

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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