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Investment Management Filing Requirements

Foley Hoag LLP

TIC Form SHL-Reporting of Foreign Holdings of U.S. Securities Due August 30, 2024

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Form SHL is a five-year mandatory benchmark survey filing commissioned by the Department of the Treasury and administered by the Federal Reserve Bank of New York (“FRBNY”) applicable to all U.S.-resident issuers with foreign...more

Seward & Kissel LLP

August 30 Deadline for TIC Form SHL

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Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

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

Stark & Stark

Navigating the New Compliance Landscape: Understanding Rule 14Ad-1 and Form N-PX Filing

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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

Akerman LLP

Initial Form N-PX Filing Deadline for Institutional Investment Managers Approaching

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Investment managers required to file Form N-PX pursuant to Rule 14Ad-1 of the Securities Exchange Act of 1934, as amended, will face their initial Form N-PX filing deadline on August 31, 2024. Although the filing obligation...more

Cooley LLP

New SEC Requirements for Form 13F Filers Effective July 1, 2024

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In late 2022, the Securities and Exchange Commission (SEC) adopted rule changes that will require institutional investment managers who file Form 13F to annually file a Form N-PX disclosing the manner in which they have voted...more

Conyers

Registering Private Funds with CIMA

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All Cayman entities that fall within the definition of “private fund” in the Private Funds Act (2021 Revision) are required to register with the Cayman Islands Monetary Authority (CIMA)....more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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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

Seward & Kissel LLP

SEC Adopts Gross Short Position and Activity Reporting by Institutional Investment Managers

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On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted new Rule 13f-2 (the “New Rule”) under Section 13(f)(2) of the Securities Exchange Act of 1934 (the “Exchange Act”), as well as related Form SHO....more

Foley Hoag LLP

Reminder: Renewal and Notice Filing Fees for Investment Advisers due by December 11, 2023

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As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 11, 2023 in order to cover such fees (with a recommendation from...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - May 2022

In this issue, we cover regulatory developments impacting the investment management sector, including updates on closed-end fund activism; new SEC proposals; and the impact of Russia sanctions on disclosure obligations and...more

Akin Gump Strauss Hauer & Feld LLP

Compliance Reminder: BE-180 Survey of Cross-Border Financial Services Transactions

U.S. persons who provided or received any financial services, such as investment advisory services, fund management or brokerage services, to or from non-U.S. persons during 2019 (“Reporters”) must file a Form BE-180 report...more

Fenwick & West LLP

Proposed Form 13F Changes Would Reduce Visibility into Stockholder Base and Activist Activities

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The U.S. Securities and Exchange Commission (SEC) has announced a proposed amendment to the filing requirements for Form 13F, which is expected to decrease the number of institutional investment managers required to report...more

Latham & Watkins LLP

SEC Proposal: Will You Still Be a 13F Filer?

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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

Proskauer Rose LLP

SEC Adopts Expedited Exemptive Relief Process for Registered Funds and BDCs

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On July 6, 2020, the Securities and Exchange Commission (the “Commission”) adopted rule amendments (the “Amendments”) to the exemptive relief application process under the Investment Company Act of 1940, as amended (the “1940...more

Faegre Drinker Biddle & Reath LLP

Securities and Exchange Commission Proposes Amendments to Form 13F for Institutional Investment Managers

On July 10, 2020, the Securities and Exchange Commission (SEC) announced that it has proposed to amend Form 13F and Rule 13f-1 to increase the reporting threshold for institutional investment managers (managers) and to...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposes to Increase 13F Threshold to $3.5 Billion

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

Locke Lord LLP

SEC Proposes Increased Threshold for Form 13F Reporting

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On July 10, 2020, the Securities and Exchange Commission (the “SEC”) proposed raising the Form 13F reporting threshold for institutional investment managers from $100 million to $3.5 billion. This threshold has not been...more

Sullivan & Worcester

SEC Proposes Increase for 13F Threshold

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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

Morgan Lewis

COVID-19’s Impact on Annual Report Filing Requirements in Japan

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This is the first in a series of alerts from Morgan Lewis’s investment management team in Tokyo that summarize how the coronavirus (COVID-19) global pandemic impacts investment fund-related businesses in Japan. ...more

A&O Shearman

UPDATED: SEC Extends Sweeping Temporary Exemptions Granted to Funds to Comply with Voting, Reporting and Prospectus Delivery...

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In an Order dated March 25, 2020, the Securities and Exchange Commission extended the exemptions offered to investment companies, business development companies (BDCs) and investment advisers grappling with challenges to the...more

Proskauer Rose LLP

SEC Provides Temporary Relief and Guidance for Companies and Funds Affected by the Coronavirus

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Exemptive Relief - The Securities and Exchange Commission (SEC) has issued an order (Order) providing temporary exemptive relief to public companies that are unable to meet filing deadlines due to circumstances related to...more

Eversheds Sutherland (US) LLP

Videocast: Form CRS delivery obligations

Beginning June 2020, the SEC will require most broker-dealers and investment advisers to file and deliver a Form CRS to new, prospective and existing customers and clients. As firms begin to prepare Form CRS, much attention...more

Vedder Price

The New Standards for Investor Protection: An Analysis of Regulation Best Interest, Form CRS and Two Interpretations of the US...

Vedder Price on

On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted three to one to approve a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - June 2019

In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more

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