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SEC Amends Registered Fund Reporting Requirements, Issues Guidance on Liquidity Risk Management Programs

The US Securities and Exchange Commission (SEC), by a 3-2 vote, recently adopted amendments to registered fund reporting requirements on Form N-PORT and Form N-CEN and provided guidance on open-end funds’ liquidity risk...more

SEC Amends Rules for Reporting Beneficial Ownership on Schedules 13D and 13G

The US Securities and Exchange Commission (SEC) adopted amendments on October 10, 2023 to the rules governing beneficial ownership reporting on Schedules 13D and 13G and provided guidance on the rules’ application. The...more

New SEC Rule Requires 13F Filers to Track and Report on Proxy Voting

Institutional investment managers that file on Form 13F must make public filings on Form N-PX to report their “say-on-pay” proxy voting. Although the compliance date for this new filing requirement is not until August 2024,...more

1940 Act Regulatory Checklists

Rule 12d1-4 under the Investment Company Act of 1940 permits funds to enter into “funds of funds” arrangements notwithstanding the prohibitions of Section 12(d)(1) of the Act of 1940, provided that certain conditions are met....more

COVID-19: SEC Staff Permits Affiliates to Purchase Debt Securities from a Mutual Fund

The staff of the US Securities and Exchange Commission (SEC) has given registered open-end management companies (mutual funds) an additional tool in the wake of the coronavirus (COVID-19) crisis to combat the potentially...more

COVID-19 Market Impact SEC Provides Short-Term Funding Affiliated Purchase Flexibility to Funds

The US Securities and Exchange Commission is providing increased flexibility to certain open-end funds and insurance company separate accounts, plus no-action relief to money market funds and their affiliates amid the...more

SEC Staff Relieves Fund Boards of Certain In-Person Voting Requirements

The US Securities and Exchange Commission staff provides new no-action relief to fund boards of directors from in-person voting requirements under certain circumstances....more

SEC Grants Section 3(c)(5)(C) Relief to Depositor of Mortgage Securitization Trusts

The US Securities and Exchange Commission staff has confirmed that a depositor of mortgage securitization trusts may rely on the exclusion from registration provided by Section 3(c)(5)(C) of the Investment Company Act of...more

SEC Exam Staff Shares Observations on Outsourced Chief Compliance Officers

Firms that use third-party CCOs or that rely on financial intermediaries that have outsourced their compliance functions should consider taking a fresh look at their compliance structure in the wake of this guidance....more

SEC Proposes Rules Affecting Funds and Advisers

Proposals would impose new disclosure requirements designed to enhance the SEC’s ability to monitor the industry. On May 20, the US Securities and Exchange Commission (SEC) unanimously approved proposals intended to...more

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