News & Analysis as of

No-Action Letters

The Financial Report, Volume 6, Number 7

by DLA Piper on

Does it ever make sense to file something with the US government when it is not clear whether the filing is required, or what might need to be filed? Recently, the staff of the US SEC’s Division of Investment Management...more

SEC Staff Relaxes Limitations under 1940 Act to Permit Certain Global “Master-Feeder” Arrangements, Although Obstacles Remain

by Dechert LLP on

The Staff of the U.S. Securities and Exchange Commission (SEC) on March 8, 2017 issued a no-action letter (Staff Letter) in response to a request from Dechert LLP for assurance under Section 12(d)(1) of the Investment Company...more

Corporate and Financial Weekly Digest - Volume XII, Issue 14

SEC/CORPORATE - SEC Division of Corporation Finance Provides Update on Conflict Minerals Rule - On April 7, the Securities and Exchange Commission Division of Corporation Finance (the Division) issued a statement...more

US Commodity Futures Trading Commission Provides Relief Associated with Swap Trade Confirmations

by Shearman & Sterling LLP on

The CFTC’s Division of Market Oversight (DMO) issued a no-action letter extending relief associated with swap trade confirmation requirements that previously was provided in CFTC Staff Letter 16-25, which expires March 31,...more

SEC Issues Update for Advisers Relying on the Unibanco No-Action Letters

Recently, the staff (Staff) of the US Securities and Exchange Commission's (SEC) Division of Investment Management issued an information update (the "Information Update") for investment advisers registered under the...more

SEC Approves U.S. Master Fund/Foreign Feeder Fund Arrangement – Section 12(d)(1)(E)

by Ropes & Gray LLP on

On March 8, 2017, the SEC staff issued a no-action letter (the “Letter”) providing assurance with respect to a plan for foreign-regulated investment companies (“Foreign Feeder Fund”) to invest exclusively in corresponding...more

Financial Services Weekly News - March 2017 #4

by Goodwin on

Editor's Note - The Battle Over the Proposed OCC FinTech Charter Continues. The Office of the Comptroller of the Currency (OCC) has released a draft supplement to its Licensing Manual explaining the process for FinTech...more

Director Cordray and Comptroller Curry speak at LendIt USA conference

by Ballard Spahr LLP on

Earlier this week, we attended the LendIt USA conference in New York City, a leading annual fintech conference, at which CFPB Director Richard Cordray and Comptroller of the Currency Thomas Curry both spoke....more

Registered Investment Advisers Take Note: New SEC Custody Rule Guidance

Registered investment advisers should take note of recent pronouncements by the staff of the SEC's Division of Investment Management (the "Division") regarding Rule 206(4)-2 (the "Custody Rule") of the Investment Advisers Act...more

Blog: SEC Continues To Grant No-Action Relief In Connection With Proxy Access Fix-It Proposals

by Cooley LLP on

The SEC has posted a number of additional Corp Fin responses to requests for no-action, as well as to requests for reconsideration of previous denials of relief, regarding shareholder proposals to amend proxy access bylaws,...more

US Commodity Futures Trading Commission Provides Time-Limited No-Action Relief for Aggregation Notice Filings for Position Limits

by Shearman & Sterling LLP on

The CFTC’s Division of Market Oversight issued a time-limited no-action letter stating that, from February 14, 2017 to August 14, 2017, it will not recommend an enforcement action for failure to file a notice when relying on...more

US Commodity Futures Trading Commission Issues Time-Limited No-Action Transition for March 1, 2017 Compliance Date for Variation...

by Shearman & Sterling LLP on

US Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a time-limited no-action letter (CFTC staff letter 17-11) which provides that, from March 1, 2017 to September 1,...more

SEC Staff Provide New Custody Rule Guidance

by Locke Lord LLP on

On February 21, 2017 the Securities and Exchange Commission (the SEC) released new guidance concerning when a registered investment adviser is deemed to have “custody” for purposes of Adviser’s Act Rule 206(4) (the Custody...more

Bridging the Week - February 2017 #2

Retail Foreign Exchange Dealer Agrees With CFTC and NFA to Cease Doing Business for Concealing Relationship With Closely Tied Market Maker - Forex Capital Markets, LLC, a retail foreign exchange dealer, and two of its...more

SEC Issues No Action Letter Regarding Canadian Companies’ Registration of Rights Offerings on MJDS Form F-7

by Dorsey & Whitney LLP on

In December 2015, the Canadian Securities Administrators (CSA) announced an amended regime for a prospectus-exempt rights offering in Canada. This amended regime allows certain public companies in Canada to conduct a...more

SEC Simplifies Filing of Broker-Dealer Annual Reports on EDGAR

The SEC has previously provided guidance on the filing of annual and supplemental reports required under Rule 17a-5 or Rule 17a-12 by broker-dealers or over-the-counter derivatives dealers on the SEC EDGAR system. However,...more

DOL Fiduciary Rule Compliance—SEC Says Brokers Can Impose Their Own Commissions on Sales of “Clean” Fund Shares

by Ropes & Gray LLP on

On January 11, 2017, the SEC staff issued a no-action letter (the “Letter”) to Capital Research and Management Company in which the staff confirmed that the restrictions of Section 22(d) of the 1940 Act do not apply to a...more

Effects of the DOL Fiduciary Rule Reach Mutual Fund Industry

The Department of Labor finalized the so-called “Fiduciary Rule” in April 2016 and announced it would go into effect in April 2017. Since the finalization of the Fiduciary Rule, the annuities, brokerage, and advisory...more

Blog: Update on proxy access proposals

by Cooley LLP on

What’s the latest on proxy access proposals? As you may recall, the line drawn so far by Corp Fin has been that, where the shareholder proposal related to initial adoption of proxy access, Corp Fin has continued to grant...more

Mutual Funds Come Clean: Brokers Can Set Fund Share Sales Charges

by Morrison & Foerster LLP on

The staff of the SEC’s Division of Investment Management effectively allowed brokers to determine the commissions they will charge their customers who buy “Clean Shares” of mutual funds. In a “no-action” letter...more

SEC Staff Allows Brokers to Set Fund Commissions with “Clean Shares”

by Perkins Coie on

The SEC’s Division of Investment Management issued a no-action letter on January 11, 2017 explicitly permitting brokers to set their own commission rates for sales of so-called “clean shares” of mutual funds. Previously, as...more

House of Representatives Passes the HALOS Act (Again), But Is It Really Necessary?

On January 10, 2017, the House of Representatives passed H.R. 79, the “Helping Angels Lead Our Startups Act” (the “HALOS Act”). The HALOS Act was originally passed by the House of Representatives as H.R. 4498 on April 27,...more

The Securities Law Crystal Ball

by Morrison & Foerster LLP on

At the beginning of each new year, we find ourselves engaged in discussions of the evolving securities regulatory landscape and the changes that we anticipate may occur. We have done this for many years now. Each January we...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The emissions cheating scandal that recently cost VW $4.3 billion and a mess of criminal indictments isn’t, it seems, confined to the Germans. We heard months ago about a similar probe into Mitsubishi, and yesterday we...more

Broker-Dealers Can Hold Customers’ Initial Checks

by Carlton Fields on

A recent SEC no-action letter gives broker-dealers more time to perform suitability and other reviews when opening certain customer accounts. The firms requesting the letter were affiliated with three different insurance...more

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