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Registered Investment Companies (RICs) Investment Management

K&L Gates LLP

Checked Swing—SEC Does Not Adopt "Swing Pricing" or a "Hard Close" for Now, but Only Provides Liquidity Guidance and Amendments to...

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EXECUTIVE SUMMARY On 28 August, 2024, the Securities and Exchange Commission (SEC) adopted amendments to reporting forms for registered investment companies (funds) that will (1) require funds to file monthly (rather than...more

Sullivan & Worcester

SEC Adopts Amendments to Form N-PORT and Form N-CEN Reporting Relating to Liquidity Risk Management; Issues Guidance on Open-End...

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On August 28, 2024, the Securities and Exchange Commission (“SEC”) adopted amendments to reporting requirements on Forms N-PORT and N-CEN that apply to certain registered investment companies, including registered open-end...more

Seward & Kissel LLP

SEC Releases Spring 2024 Regulatory Agenda, Plans to Re-Propose Several Key Rules

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The Office of Information and Regulatory Affairs, a division of the Office of Management and Budget, released its Spring 2024 Unified Agenda of Regulatory and Deregulatory Actions, which includes short- and long-term...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

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

Proskauer Rose LLP

SEC Adopts Amendments to Fund Names Rule

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On September 20, 2023, the Securities and Exchange Commission (the “SEC”) voted to adopt final amendments to modernize Rule 35d-1 of the Investment Company Act of 1940, as amended (the “1940 Act”). This rule, commonly...more

Morgan Lewis

ETF Roundup – Issue 7 December 2021

Morgan Lewis on

UPDATE ON CRYPTO ASSETS IN ETFS - In 2018, the US Securities and Exchange Commission’s Division of Investment Management staff penned a letter to the Investment Company Institute and the Securities Industry and Financial...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - December 2021

In this issue, we cover regulatory developments impacting the investment management sector, including proposed legislation supported by the Investment Company Institute to address challenges for closed-end funds; the...more

Faegre Drinker Biddle & Reath LLP

SEC Proposes Rules for Enhanced Reporting of Proxy Voting by Registered Investment Companies and Reporting on Executive...

On September 29, 2021, the U.S. Securities and Exchange Commission (SEC) proposed amendments to Form N-PX to provide greater transparency to the information registered management investment companies (Funds) report about...more

Goodwin

Department Of Labor Finalizes Regulation Requiring Fiduciary Investment Decisions To Be Based Solely On Pecuniary Factors

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On October 30, 2020, the Department of Labor (“DOL”) released its final amended regulation on investment duties under Section 404(a)(1)(A) and (B) of ERISA. The final regulation substantially reworks the DOL’s original...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

A&O Shearman

SEC Emergency Order Bolsters Fund Liquidity by Expanding Ability to Borrow From Affiliates, Enter Into Interfund Lending...

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In response to the outbreak of the COVID-19 coronavirus disease, the Securities and Exchange Commission took extraordinary action to bolster liquidity for registered investment companies through at least June 30, 2020. In an...more

Troutman Pepper

Investment Management Update - January 2020

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SEC Proposes to Update Accredited Investor Definition to Increase Access to Investments - On December 18, 2019, the Securities and Exchange Commission (SEC) proposed amendments to the definition of “accredited investor” in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - January 2020

In this issue, we summarize regulatory, litigation and industry developments from October 2019 to early January 2020 impacting the investment management sector, including SEC action on use of derivatives by registered...more

Vedder Price

Investment Services Regulatory Update - January 2019

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes New Fund-of-Funds Rule – On December 19, 2018, the SEC proposed new Rule 12d1-4 under the Investment Company Act of 1940, which, if...more

Akin Gump Strauss Hauer & Feld LLP

Investment Management Special Report - 2018-19 Compliance Developments & Calendar for Private Fund Advisers

Despite the new administration, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have both continued to make novel interpretations and to bring enforcement actions that break...more

Vedder Price

Investment Services Regulatory Update - July 2018

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - PROPOSED RULES - SEC Proposes New Rule to Permit Certain ETFs to Operate Without an Exemptive Order - On June 28, 2018, the SEC issued a proposed new rule under the...more

Vedder Price

Investment Services Regulatory Update - May 2018

Vedder Price on

SEC Proposes Amendments to Auditor Independence Rules to Address Certain Lending Relationships - Summary - On May 2, 2018, the SEC issued proposed amendments to its auditor independence rules concerning the...more

Dechert LLP

SEC Staff Extends Effectiveness of No-Action Relief on Auditor Independence and the “Loan Provision”

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The U.S. Securities and Exchange Commission’s Division of Investment Management (SEC Staff) on September 22, 2017 extended indefinitely the effectiveness of no-action relief granted a year earlier with respect to the...more

Vedder Price

Investment Services Regulatory Update - September 2017

Vedder Price on

Market and Product Developments - Securities Industry Implements T+2 Settlement Cycle - On September 5, 2017, the securities industry transitioned to a shorter settlement cycle for most broker-dealer securities...more

Dechert LLP

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

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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

Dechert LLP

SEC Adopts New Rules and Rule Amendments to: (1) Require Liquidity Risk Management Programs for Registered Open-End Investment...

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Earlier today, the U.S. Securities and Exchange Commission (SEC) unanimously adopted a new rule and amendments to certain rules and forms that will require registered open-end investment companies, including mutual funds and...more

Broker-Dealer Compliance + Regulation

SEC Proposes Business Continuity and Transition Rules for Advisers While Staff Publishes Similar Guidance for Funds

The SEC’s Division of Investment Management published regulatory guidance on June 28, 2016, highlighting the need for registered investment company complexes to review their business continuity plans to ensure they are...more

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