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Libor Broker-Dealer

SEC Compliance Consultants, Inc. (SEC³)

Tips for SEC Exam Preparedness

For your reading pleasure, we present a list of tips for surviving a routine SEC Examination. This list has been compiled by SEC3 employees including ex-SEC examiners. It is not to be considered all-inclusive and is provided...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - August 2023

Closed-End Fund Activism Update - Activist investors continue to take large positions in closed-end funds and engage in disruptive activity that may be harmful to long-term shareholders of retail closed-end funds. This...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions - July 2023

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REGULATORY UPDATES - Recent SEC Leadership Changes - The Securities and Exchange Commission (the “SEC”) announced the appointment of Deborah J. Jeffrey as Inspector General effective May 7, 2023. Prior to this...more

Dechert LLP

SEC Division of Examinations Releases 2023 Priorities

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The Securities and Exchange Commission’s Division of Examinations (EXAMS) published its report on 2023 Examination Priorities on February 7, 2023. The 2023 Examination Priorities continue to reflect an examination program...more

Morrison & Foerster LLP

SEC Division of Examinations’ 2023 Exam Priorities – A Continued Focus on Private Funds, Regulation Best Interest, ESG, and Crypto

On February 7, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMs) announced its 2023 Examination Priorities (the “Priorities”), which highlight areas it expects to target in 2023...more

Tonkon Torp LLP

SEC Division of Examinations Announces 2023 Priorities

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On February 7, 2023, the Securities and Exchange Commission’s Division of Examinations announced its fiscal year 2023 examination priorities. This year, the Division continues its focus on protecting investors by prioritizing...more

Latham & Watkins LLP

SEC Staff Issues Key Considerations on LIBOR Transition

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As a major LIBOR transition milestone approaches, a Staff Statement provides key considerations for market participants regarding their obligations. On December 7, 2021, the Staff of the Securities and Exchange...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Goodwin

Tenth Circuit Upholds District Court’s Ruling Finding No Breach of Fiduciary Duties in Section 36(b) Case

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In This Issue. The federal bank regulators published frequently asked questions concerning the London Interbank Offered Rate transition; the Consumer Financial Protection Bureau (CFPB) confirmed an effective date for two...more

Moore & Van Allen PLLC

UPDATED: Term SOFR vs BSBY vs Ameribor in the Loan Market

This is an update to a previous post. This update highlights the formal endorsement of Term SOFR by the ARRC, expands the discussion to include Ameribor and dives more deeply into the issues associated with Term SOFR swaps...more

ArentFox Schiff

Repo Market Disruptions: In Reverse (Part II)

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Based upon the records of the New York Fed and the Federal Reserve Economic Data (FRED) of the St. Louis Fed, the level of reverse repo activity on June 17th -18th reached unprecedented levels. It was previously reported...more

King & Spalding

SEC Division of Examinations – 2021 Priorities

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On March 3, 2021, the SEC’s Division of Examinations (“Division” or “EXAMS”) published its annual Examination Priorities Report, which identified eight primary areas of focus for Fiscal Year 2021. While many of these...more

Bressler, Amery & Ross, P.C.

ESG Task Force, Emerging Risk Team, Exam Priorities for 2021 and Other Highlights from the SEC

It is clear that environmental, social, and governance (“ESG”) issues will be an “enhanced focus” for the SEC in 2021. See, the regulator’s recent announcement of an ESG task force and the Division of Examinations priorities...more

Orrick, Herrington & Sutcliffe LLP

The SEC’s 2021 Examination Priorities Provide Firms With a Roadmap to Compliance

Last week, the Securities and Exchange Commission’s newly renamed Division of Examinations (formerly known as the Office of Compliance Inspections and Examinations) published its 2021 Examination Priorities (“Exam...more

Fox Rothschild LLP

New SEC Division Undertakes 2021 Examination Priorities

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On December 17, 2020, SEC created the Division of Examinations by renaming the now defunct, Office of Compliance Inspections and Examinations, making it the SEC’s 6th Division joining Enforcement, Corporation Finance, Trading...more

Dechert LLP

LIBOR: First They Blinked and Now Some Hope, But a New Problem and It’s Big

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First, the ARRC, playing Charlton Heston, playing Moses, brings down from on high the ten commandments of SOFR and lo, we were sore afraid and with veneration, professed we had no God but SOFR.  A solution of sorts to a...more

Jones Day

FINRA Shares LIBOR Transition Preparation Practices of Broker-Dealers - FINRA has published helpful survey results on the...

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On August 5, 2020, FINRA published Regulatory Notice 20-26, summarizing the results of a survey FINRA conducted of a representative cross-section of member firms, including firms with significant trading volumes or positions...more

Dechert LLP

SEC Publishes OCIE Risk Alert on LIBOR Transition Preparedness Examination Initiative

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The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations issued a National Exam Program Risk Alert on June 18, 2020 (Risk Alert), which introduces an examination initiative on the upcoming...more

A&O Shearman

SEC Identifies LIBOR Preparedness as an Examination Priority

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On June 18, 2020, the Securities Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) announced the details of an examination initiative specifically focused on LIBOR preparedness. OCIE has...more

Jones Day

SEC Staff Announces Initiative on LIBOR Transition

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The Situation: The SEC's Office of Compliance Inspections and Examinations ("OCIE") intends to examine registrants to assess preparation for the expected discontinuation of LIBOR and the transition to alternative reference...more

Katten Muchin Rosenman LLP

LIBOR Preparedness Exams Are Coming – Is Your Firm Ready?

Key Points - - The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) recently released a Risk Alert warning investment advisers, broker-dealers, investment companies,...more

Goodwin

Financial Services Weekly Roundup: Code Libor – SEC And OCIE Issue Risk Alert In Preparation Of Libor Discontinuation

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In This Issue. The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert about the scope and content of examinations OCIE plans to conduct of various...more

Eversheds Sutherland (US) LLP

Videocast: Asset management regulation in 2020 videocast series – Regulators step up pressure to implement LIBOR transition plans

Regulators are increasing pressure on financial institutions to demonstrate that they are proactively addressing the transition away from the London Interbank Offered Rate (LIBOR). The New York State Department of Financial...more

Dorsey & Whitney LLP

SEC Exam Priorities For RIAs and ICs

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The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more

Eversheds Sutherland (US) LLP

The heat is on - Regulators step up pressure to implement LIBOR transition plans

Regulators are increasing pressure on financial institutions to demonstrate that they are proactively addressing the transition away from LIBOR.  On December 23, 2019, the New York State Department of Financial Services...more

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