News & Analysis as of

Non-Enforcement

Conflict Minerals Update – SEC Releases Guidance Following District Court Decision

by White & Case LLP on

On April 3, 2017, the US District Court for the District of Columbia (the "Court") entered a final judgment in National Association of Manufacturers, et al. v. Securities and Exchange Commission,1 ruling that Section 1502 of...more

"SEC Staff Provides Relief From Conflict Minerals Rule"

In statements released on April 7, 2017, the acting chairman of the Securities and Exchange Commission (SEC), Michael S. Piwowar, and the SEC's Division of Corporation Finance provided welcome news to companies concerning the...more

Department of Labor Adopts Temporary Non-Enforcement Policy for Fiduciary Rule

by Ropes & Gray LLP on

On March 10, 2017, the U.S. Department of Labor (the “DOL”) issued Field Assistance Bulletin No. 2017-01, announcing a temporary non-enforcement policy for non-compliance with its fiduciary rule. The non-enforcement policy...more

FDA's Proposed Oversight of Laboratory Developed Tests - Industry Impact

by Foley & Lardner LLP on

The U.S. Food and Drug Administration (FDA) recently announced that the Agency is lifting its enforcement discretion over high-risk laboratory developed tests (LDTs). The FDA’s “LDT Guidance” was reviewed in detail in my...more

A Compilation of Enforcement and Non-Enforcement Actions

by Foley & Lardner LLP on

Renewed Call for Investment Adviser User Fees - As we reported in previous editions of our Investment Management Newsletter, various persons have proposed that a user fee be imposed on SEC registered investment...more

A Compilation of Enforcement and Non-Enforcement Actions - November 08, 2013

by Foley & Lardner LLP on

Non-Enforcement Matters - SEC Focused on Compliance Programs - SEC Beefing Up its Risk and Examinations Office - SEC Guidance on Valuation of Portfolio Securities - Affiliated Exchange-Traded Funds May...more

A Compilation of Enforcement and Non-Enforcement Actions - October 30, 2013

by Foley & Lardner LLP on

Non-Enforcement Matters: - No Rush to Advertise by Hedge Funds - Updated Guidance From the SEC - Results of Dodd-Frank Legislation on Investment Adviser Registration Numbers Enforcement...more

A Compilation of Enforcement and Non-Enforcement Actions - September 30, 2013

by Foley & Lardner LLP on

Non-Enforcement Matters - SEC to Monitor Fund Performance Claims - Suit Against Exchange Traded Funds’ Investment Adviser Dismissed - Counterparty Risk Management Practices for Mutual...more

Religious Institutions Update: August/September 2013

by Holland & Knight LLP on

On August 2, 2013, the White House's Office of Management and Budget issued a memorandum instructing federal agencies to take steps to carry out President Obama's executive order (E.O. 13559 (Nov. 17, 2010)) adopting several...more

A Compilation of Enforcement and Non-Enforcement Actions - August 30, 2013

by Foley & Lardner LLP on

Non-Enforcement Matters: - Private Fund Issuers’ Use of New SEC Rule 506(c) Hardly a “Slam Dunk” - Advisers Need to Revisit Their Business Continuity Plans. Enforcement Matters: - Registered...more

A Compilation of Enforcement and Non-Enforcement Actions - July 31, 2013

by Foley & Lardner LLP on

Non-Enforcement Matters - Insider Trading in Mutual Fund Shares - Incentive for Whistleblowers to Bypass Internal Reporting - SEC Announces Compliance Outreach Sessions - Implementation of FATCA Reporting...more

A Compilation of Enforcement and Non-Enforcement Actions - July 01, 2013

by Foley & Lardner LLP on

Re: Possible SRO for Investment Advisers and Fiduciary Standard for Broker-Dealers — What Others Are Saying - In the ongoing debate over whether a supervisory regulatory agency, other than the SEC, should be delegated...more

A Compilation of Enforcement and Non-Enforcement Actions - May 01, 2013

by Foley & Lardner LLP on

* Non-Enforcement Matters: - Legislation Reintroduced to Charge Investment Advisor User Fees - SEC Examination Program for Newly Registered Investment Advisers Reveals Common Areas of Concern - Recent...more

A Compilation of Enforcement and Non-Enforcement Actions - January 31, 2013

by Foley & Lardner LLP on

In This Issue: Non-Enforcement Matters - FINRA Announces Regulatory and Examination Priorities for 2013 - SEC Previous Hedge Fund Enforcement Trends for 2013 Enforcement Matters - Another...more

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