Stealth Lawyer: Eli Broverman, Financial Startup Co-Founder
The Division of Investment Management (“Division”) of the U.S. Securities and Exchange Commission (“SEC”) recently published guidance (“Guidance”) addressing steps that funds and fund advisers should consider in light of...more
The SEC's Division of Investment Management has issued a No-Action Letter that expands the pool of possible employee investors in in-house private funds. While the SEC's new in-house investment flexibility may help those who...more
Beginning with the period ended December 31, 2013, the U.S. Department of the Treasury expanded the scope of the financial institutions required to report cross-border claims, liabilities and short-term securities holdings on...more
To many, the words “custody” and “hide” would seem to have absolutely nothing in common. Etymologically speaking, however, they are cognates (blood relatives). Their common ancestor is the Proto-Indo-European etymon –...more
I was thinking my disgorgement post would be the last one of the year but, you know, it’s hard to stop. On Christmas Eve, the Boston Globe published a nice profile of Paul Levenson, the newly installed head of the SEC’s...more
Agricultural sector companies, and companies with large agricultural supply chains, face new scrutiny from investors and other stakeholders concerning human rights-related risks in their corporate supply chains. Key issues...more
Hong Kong introduces a new electronic trading regulatory regime with effect from 1 January 2014, when all licensed and registered persons in Hong Kong that conduct electronic trading of securities and futures contracts listed...more
The five US financial agencies (“Agencies”) have approved jointly prepared final regulations (“Final Rules”) to implement the prohibitions on engaging in proprietary trading and investment in or sponsorship of a private...more
When my wife and I bought our house, there were quite a few things that the previous owner forgot to tell us such as the fact they never bothered to pull the pipes from the dental office run by a previous owner 20 years...more
On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity...more
Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more
The latest edition of Financial Services Europe and International Update from Dechert’s Financial Services Practice covers the most recent regulatory developments.
In This Issue:
- Part A – Regulation of Financial...more
The SEC’s Division of Investment Management has closed a potential loophole in the federal securities laws through which some fund advisers may have attempted to squeeze to avoid registration....more
The SEC Division of Investment Management has issued additional guidance that is meant to assist institutional investment managers that wish to request confidential treatment, or CT requests, for certain information reported...more
Can two affiliated ETFs merge in reliance on Rule 17a-8 under the Investment Company Act despite representations they made to obtain exemptive relief from the Commission? That’s the question addressed in a recent Guidance...more
Norm Champ, the SEC’s Director of the Division of Investment Management, recently gave a speech addressing the SEC’s priorities regarding hedge fund managers.
The Division of Investment Management (Division) of the U.S. Securities and Exchange Commission (SEC) recently posted an IM Guidance Update that expands the applicability of an exception from the Custody Rule (as defined...more
The Staff of the Division of Investment Management of the SEC has published a Guidance Update with respect to Disclosure and Compliance Matters for Investment Company Registrants that Invest in Commodity Interests....more
Investment managers may be well served to file their upcoming Form 13F reports (due next Wednesday, August 14th) early this quarter. That is because a new EDGAR filing format went into effect on May 20, 2013, pursuant to...more
It has been a busy summer for securities regulators in Hong Kong and on the Mainland. Recent press coverage indicates that the regulators are closer now to making the Mutual Fund Recognition Scheme (the “Scheme”) a reality,...more
The SEC’s Division of Investment Management recently offered guidance on the custody of privately offered securities....more
It is well-known that high-profile jurisdictions such as California and New York City have in certain instances placed lobbyist registration requirements on investment managers that solicit investment advisory business from...more
The "family office" is back in vogue. The dramatic increase in wealth creation during the last thirty years has given rise to a new generation of Rockefellers, Mellons, and Phipps. Today, families with sufficient wealth –...more
In This Issue:
- Single Charge for Investment Management Services Found Not Subject to New York Sales Tax.
- Remote Vendor Not “Doing Business” in New York.
- Nonresident Partner’s Loss from 2005...more
Board Oversight of Distribution and Financial Intermediaries -
One of the SEC’s stated focuses is on payments for “distribution in guise.” Mutual funds are only permitted to pay for distribution of their shares if...more
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