News & Analysis as of

Securities and Exchange Commission (SEC) Aggregation Rules

Foley & Lardner LLP

SEC Amends Rule 14a-8 to Modernize Shareholder Proposal Requirements

Foley & Lardner LLP on

On September 23, 2020, the Securities and Exchange Commission (“SEC”) announced that it had adopted amendments to Rule 14a-8 under the Securities Exchange Act of 1934 (the “Amendments”). Rule 14a-8 governs the eligibility, on...more

Carlton Fields

Related Decisions: Three Recent Cases Emphasize Breadth of “Related Wrongful Acts”

Carlton Fields on

Third-party liability policies often include aggregation clauses. As the name suggests, these clauses aggregate “related claims” or “interrelated wrongful acts” into one claim or occurrence....more

Cadwalader, Wickersham & Taft LLP

CFTC Finalizes Aggregation of Positions Rule

On December 5, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule amending the requirements to aggregate positions subject to a CFTC-set speculative position limit (“Final Aggregation...more

Morrison & Foerster LLP

Following the Wisdom of the Crowd? A Look at the SEC’s Final Crowdfunding Rules

In this alert, we provide a detailed overview of the final rules, Regulation Crowdfunding, which will be applicable to crowdfunding offerings conducted in reliance on Section 4(a)(6) of the Securities Act of 1933 as amended...more

Dechert LLP

CFTC Proposes New Position Limits for Futures, Options, and Swaps and Amended Aggregation Requirements

Dechert LLP on

Introduction - The U.S. Commodity Futures Trading Commission (“CFTC”) has proposed a comprehensive set of regulations imposing speculative position limits on exchange-traded futures and options contracts and...more

Broker-Dealer Compliance + Regulation

SEC Won’t Object To Aggregation of Certain Client Investments in Private Funds

In a Guidance Update published this week, the SEC’s Division of Investment Management said that it would not object if related investment advisors registered jointly with the SEC and operating a single advisory business...more

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