News & Analysis as of

Securities and Exchange Commission (SEC) Registered Investment Companies (RICs)

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

Seward & Kissel LLP

SEC Enforcement Action Rundown

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Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of enforcement actions relating to recordkeeping failures,...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

Paul Hastings LLP

SEC Adopts Amendments To Regulation S-P

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

Seward & Kissel LLP

SEC Releases Materials on T+1 Settlement Cycle Adoption in Advance of May Compliance Date

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Who may be interested: Registered-Investment Companies; Investment Advisers; Broker-Dealers - Quick Take: In May 2023, the SEC adopted several Rules and Rule amendments which, among other things, shorten the standard...more

WilmerHale

SEC Adopts New Rules That Will Require More Market Participants to Register as Dealers

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On February 6, 2024, by a vote of 3-2 along party lines, the Securities and Exchange Commission (the SEC or the Commission) adopted Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (the Exchange Act), which...more

Goodwin

SEC EXAMS Division Announces 2024 Priorities Ahead of Schedule

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On October 16, 2023, the SEC’s Division of Examinations (EXAMS) published its exam priorities for 2024. The timing is notable, with the release coming several months ahead of the typical timeline and only eight months after...more

Morrison & Foerster LLP

U.S. SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the...more

McDermott Will & Emery

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the US Securities and Exchange Commission (SEC) adopted amendments to Sections 13(d) and 13(g) of the Securities Exchange Act of 1934, which among other things, accelerate the filing deadlines for...more

Seward & Kissel LLP

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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Who may be interested: Registered Investment Companies, Investment Advisers. Quick Take: The SEC adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Exchange...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

Seward & Kissel LLP

SEC Adopts Money Market Fund Reforms

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Who may be interested: Registered Investment Companies; Investment Advisers - Quick Take: The SEC adopted amendments to Rule 2a-7 governing money market funds under the Investment Company Act to improve the transparency...more

Seward & Kissel LLP

SEC Division of Examinations Releases its 2023 Examination Priorities

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Who may be interested: Registered Investment Companies; Directors of Registered Investment Companies; and Investment Advisers. Quick Take: Registered funds should expect the staff of the Division of Examinations (Staff)...more

Vinson & Elkins LLP

SEC 2023 Examination Priorities

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On February 7, 2023, the Securities and Exchange Commission’s Division of Examination (the “Division”) announced its 2023 examination priorities to “provide insights into its risk-based approach, including the areas it...more

Goodwin

SEC Adopts Amendments to Shareholder Reports and Advertising Rules

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On October 26, 2022, the US Securities and Exchange Commission (SEC) voted to adopt rule and form amendments (the “final rules”) related to (1) shareholder reports of mutual funds and exchange-traded funds (ETFs) registered...more

Mayer Brown Free Writings + Perspectives

SEC Open Meeting Announced

The Securities and Exchange Commission announced an open meeting to be held on November 2, 2022 to discuss several matters, some proxy related. The SEC will consider whether to adopt new rules and form amendments...more

UB Greensfelder LLP

So You Received A Rule 4111 Letter From FINRA Informing You That You’re Presumptively A “Restricted Firm.” Now What??

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It’s always exciting to watch something that you just know will be deemed by later generations to be an historic event. I mean, I distinctly remember watching Neil Armstrong on TV taking his first steps on the moon, or the...more

Moore & Van Allen PLLC

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Seward & Kissel LLP

SEC Proposes Amendments to Fund “Names Rule” and Proposes Amendments Concerning Fund ESG Investment Practices

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On May 25, 2022, the SEC proposed amendments to Rule 35d-1, the fund “Names Rule,” (Names Rule Amendments) and, separately, proposed amendments to several rules and forms that would require additional disclosure for funds and...more

BCLP

The SEC’s Continued Efforts to Dive Feet First into Climate Control and ESG Initiatives

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On May 25, 2022, the U.S. Securities and Exchange Commission (“SEC”) provided notice of proposed rulemaking aimed at Investment Advisers (“Advisers”), Investment Companies and Business Development Companies (collectively...more

Eversheds Sutherland (US) LLP

SEC proposes enhanced investment company and investment adviser ESG disclosures

On May 25, 2022, the Securities and Exchange Commission (SEC) proposed significant rule and form amendments under the Investment Company Act of 1940, as amended (1940 Act) and the Investment Advisers Act of 1940, as amended...more

UB Greensfelder LLP

The 411 On FINRA Rule 4111

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Well, Memorial Day is just past us, so we all know what that means: it’s time for FINRA to conduct its first annual assessment of its member firms to determine whether they should be branded a “Restricted” firm under new Rule...more

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