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Disclosure Requirements Registered Investment Companies (RICs)

Foley Hoag LLP

Reminder: New Say-on-Pay Disclosures for Institutional Investment Managers Now Effective

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The Securities and Exchange Commission (“SEC”) adopted amendments to Form N-PX on November 2, 2022. Previously, Form N-PX applied solely to registered investment companies (i.e., mutual funds, exchange-traded funds and...more

Morrison & Foerster LLP

U.S. SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the...more

McDermott Will & Emery

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the US Securities and Exchange Commission (SEC) adopted amendments to Sections 13(d) and 13(g) of the Securities Exchange Act of 1934, which among other things, accelerate the filing deadlines for...more

Seward & Kissel LLP

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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Who may be interested: Registered Investment Companies, Investment Advisers. Quick Take: The SEC adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Exchange...more

Proskauer Rose LLP

SEC Adopts Amendments to Fund Names Rule

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On September 20, 2023, the Securities and Exchange Commission (the “SEC”) voted to adopt final amendments to modernize Rule 35d-1 of the Investment Company Act of 1940, as amended (the “1940 Act”). This rule, commonly...more

Moore & Van Allen PLLC

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Seward & Kissel LLP

SEC Proposes Amendments to Fund “Names Rule” and Proposes Amendments Concerning Fund ESG Investment Practices

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On May 25, 2022, the SEC proposed amendments to Rule 35d-1, the fund “Names Rule,” (Names Rule Amendments) and, separately, proposed amendments to several rules and forms that would require additional disclosure for funds and...more

BCLP

The SEC’s Continued Efforts to Dive Feet First into Climate Control and ESG Initiatives

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On May 25, 2022, the U.S. Securities and Exchange Commission (“SEC”) provided notice of proposed rulemaking aimed at Investment Advisers (“Advisers”), Investment Companies and Business Development Companies (collectively...more

Eversheds Sutherland (US) LLP

SEC proposes enhanced investment company and investment adviser ESG disclosures

On May 25, 2022, the Securities and Exchange Commission (SEC) proposed significant rule and form amendments under the Investment Company Act of 1940, as amended (1940 Act) and the Investment Advisers Act of 1940, as amended...more

Goodwin

SEC Proposes ESG Disclosure Rules for Investment Advisers and Investment Companies

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On May 25, 2022, the U.S. Securities and Exchange Commission (the “SEC”) proposed a package of new rules to address and enhance investor disclosure practices, and related policies and procedures, regarding Environmental,...more

Morrison & Foerster LLP

New Climate-Related Financial Disclosures for Private Companies and LLPs

Companies and limited liability partnerships (LLPs) “with the greatest economic and environmental impact” are now subject to the legal requirement to assess their climate risks and disclose climate-related financial...more

Fox Rothschild LLP

What Do ESG Funds and Fat-Free Milk Have in Common? Not Enough, According to SEC Chairman Gary Gensler

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The Securities and Exchange Commission (SEC) proposed changes on May 25, 2022, to the rules and disclosure forms pertaining to the ways advisers and funds incorporate Environmental, Social, and Governance (ESG) factors into...more

Dechert LLP

Dechert Cyber Bits - Issue 8

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SEC Proposes and Seeks Comments on New Cybersecurity Rules - At an open meeting on February 9, 2022, the Securities and Exchange Commission (“SEC”) voted three-to-one to propose new and amended rules regarding cybersecurity...more

Burr & Forman

SEC Proposes Cybersecurity Rule for Advisers, Investment Companies

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On February 9, the SEC proposed new cybersecurity risk management regulations for investment advisers, registered investment companies (funds), and business development companies....more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - December 2021

In this issue, we cover regulatory developments impacting the investment management sector, including proposed legislation supported by the Investment Company Institute to address challenges for closed-end funds; the...more

Goodwin

U.S. Securities and Exchange Commission Division of Examinations Publishes Observations from its Registered Investment Company...

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The staff of the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (the “Division”) recently published a risk alert spotlighting observations from its “RIC Initiatives” — 200+ examinations of mutual...more

Goodwin

SEC Adopts Amendments to Rules Governing Financial Disclosures on Material Acquisitions and Dispositions of Businesses

Goodwin on

In an effort to reduce the complexity and compliance costs of financial disclosures for significant acquisitions or dispositions of businesses, the SEC has adopted amendments to the applicable rules, reducing the scope of...more

Dechert LLP

SEC Streamlines Financial Disclosure Requirements Applicable to Business Acquisition and Disposition Transactions

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On May 21, 2020, the U.S. Securities and Exchange Commission (the “SEC”) announced adoption of updates to the financial disclosure requirements of Regulation S-X and related rules applicable to the acquisition and disposition...more

McDermott Will & Emery

COVID-19 Considerations for Private Investment Funds

The recent coronavirus pandemic presents significant challenges for private investment fund sponsors. Navigating these challenges requires proactively addressing risks and thoughtfully considering the following issues...more

Dorsey & Whitney LLP

SEC Takes Targeted Action to Assist Funds and Advisers, Permits Virtual Board Meetings and Provides Conditional Relief from...

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On March 13, 2020, the Securities and Exchange Commission (SEC), indicating that it is closely monitoring the impact of coronavirus on investors, funds and advisers, announced regulatory relief for funds and investment...more

Dechert LLP

CFTC Finalizes Regulation Amendments: Certain Registered and Exempt CPOs and CTAs Need to Take Action

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The Commodity Futures Trading Commission published in the Federal Register on December 10, 2019 several amendments to the regulatory framework applicable to certain commodity pool operators (CPOs) and commodity trading...more

Vedder Price

Investment Services Regulatory Update - June 2019

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Investment Services Regulatory Update – New Rules, Proposed Rules, Guidance and Alerts – New Rules – SEC Adopts Rules and Interpretations Concerning the Standard of Conduct for Broker-Dealers and Investment Advisers - ...more

Proskauer Rose LLP

SEC Proposes Rule Changes with Potential Benefits for REITs, Funds, and Business Development Companies

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The Securities and Exchange Commission ("SEC" or "Commission") recently proposed a number of changes to Regulation S-X and related rules and forms that could significantly streamline the requirements for filing financial...more

Eversheds Sutherland (US) LLP

Fund of funds flexibility - What’s important to BDCs and closed-end funds in the SEC’s rule proposal, including a request for...

On December 19, 2018, the US Securities and Exchange Commission (SEC) issued a release (the Release) proposing new rule 12d1-4 (the Proposed Rule) and related amendments to streamline and enhance the regulatory framework that...more

Dechert LLP

SEC Proposes Changes to Regulatory Framework of Fund of Funds Arrangements and Requests Comments on Potential Changes to AFFE...

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The Securities and Exchange Commission voted on December 19, 2018 to propose Rule 12d1-4 (proposed rule) and related amendments to the regulatory framework governing funds that invest in other funds (“fund of funds”...more

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