New Rule 14Ad-1 takes effect on July 1, 2024, with filing of Form N-PX due on August 31, 2024, for votes during the July 1, 2023 to June 30, 2024 reporting period. ...more
The Securities and Exchange Commission adopted rule and form amendments that will require institutional investment managers who file Form 13F to use Form N-PX to report how they voted proxies on executive compensation (or...more
Institutional investment managers that file on Form 13F must make public filings on Form N-PX to report their “say-on-pay” proxy voting. Although the compliance date for this new filing requirement is not until August 2024,...more
The SEC recently proposed to require investment managers to report short sale information on a monthly basis if such activity exceeds certain thresholds, and to require broker dealers to begin to mark “buy to cover” trades...more
INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and...more
REGULATORY UPDATES - SEC Adopts Amendments to Exemptive Applications Procedures - On July 6, 2020, the Securities and Exchange Commission (the “SEC”) announced the adoption of rule amendments that establish an expedited...more
On July 10th, the SEC proposed amendments to Exchange Act Rule 13f-1 that would raise the Form 13F reporting threshold from $100 million to $3.5 billion. If effected, this would be the first change to the reporting threshold...more
Proposed Amendments to Form 13F Would Increase the Reporting Threshold from $100 Million to $3.5 Billion, Among Other Changes On July 10, 2020, the U.S. Securities and Exchange Commission (SEC) issued a proposed rule (the...more
The SEC proposes a welcome and significant increase in the 13F reporting threshold from US$100 million to US$3.5 billion. On July 10, 2020, the US Securities and Exchange Commission (SEC) released a proposed rule amendment...more
On July 10, 2020, the Securities and Exchange Commission (SEC) proposed to increase the filing threshold for Form 13F to $3.5 billion (35 times larger than the current $100 million threshold), revise the requirements for...more
On July 10, 2020, the Securities and Exchange Commission (“SEC”) proposed significantly increasing the reporting threshold requiring the filing of a Form 13F to $3.5 billion, a 35-fold increase from the current threshold....more
The SEC has proposed to amend Form 13F to update the reporting threshold for institutional investment managers from $100 million to $3.5 billion. The threshold has not been adjusted in over 40 years. Section 13(f) of the...more
The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more
For new and growing investment advisers, 2019 may bring an additional filing obligation. Section 13(f) of the Securities Exchange Act of 1934 has long required certain investment advisers to file reports of their holdings...more
This alert contains a summary of the primary annual and periodic compliance-related obligations that may apply to investment advisers registered with the Securities and Exchange Commission (the “SEC”) or with a particular...more
The U.S. federal securities laws and the rules of U.S. self regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more
Investment Advisers - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their compliance...more
The U.S. federal securities laws and the rules of U.S. self-regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more
Investment Advisers - Annual Compliance Reviews: All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least...more