News & Analysis as of

Chief Compliance Officers No-Action Letters

Proskauer Rose LLP

SEC Issues No-Action Relief Increasing Flexibility for Certain In-Person Director Voting Requirements

Proskauer Rose LLP on

On February 28, 2019, the staff of the Division of Investment Management (the "Staff") of the Securities and Exchange Commission (the "SEC") issued a no-action letter permitting the board of directors of a registered fund or...more

Mayer Brown Free Writings + Perspectives

SEC Permits Fund Board Reliance on CCOs

On October 12, 2018, the Securities and Exchange Commission’s Division of Investment Management issued a no-action letter permitting a fund’s board of directors (“Board”) to rely upon quarterly compliance certifications...more

K&L Gates LLP

SEC Staff No-Action Letter Eases Board’s Burden in Reviewing Affiliated Transactions

K&L Gates LLP on

On October 12, 2018, the staff of the Division of Investment Management (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued a no-action letter to the Independent Directors Council (“IDC”) (“IDC Letter”)...more

Kramer Levin Naftalis & Frankel LLP

SEC Staff Allows Boards to Rely on CCO Determinations for Various Affiliated Transactions

In a no-action letter (the Relief) issued on Oct. 12, 2018, to the Independent Directors Council, the Securities and Exchange Commission staff (the Staff) confirmed that they would not recommend enforcement if a fund’s board...more

A&O Shearman

SEC Staff Eases Fund Director Burdens

A&O Shearman on

For decades, mutual fund directors have turned to quarterly reports on affiliated cross trades, participation in affiliated underwritings and affiliated brokerage; the reports themselves state that the trades are in...more

Morrison & Foerster LLP

SEC Staff Allows Fund Boards to Rely on CCO Reports

Morrison & Foerster LLP on

On October 12, 2018, the staff of the SEC’s Division of Investment Management issued a no-action letter to the Independent Directors Council (“IDC”) agreeing that the staff will not recommend enforcement if, in lieu of making...more

Morgan Lewis

Broker-Lite: FINRA Built It, But Will They Come?

Morgan Lewis on

On August 18, 2016, the US Securities and Exchange Commission (SEC) approved a new Financial Industry Regulatory Authority (FINRA) rule series intended as a “lite” framework for the registration and regulation of brokers that...more

Orrick - Finance 20/20

CFTC No-Action Relief for Compliance Reporting

On March 28, the CFTC issued a no-action letter providing limited relief, in certain circumstances, from the requirement that chief compliance officers of futures commission merchants prepare and submit an Annual Report....more

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