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Out With the Old, in With the New – SEC Scraps Swing Pricing Proposal, Removes Redemption Gates, and Mandates Liquidity Fees for...

In a surprising change, the SEC heeded the cacophony of opposition to swing pricing, but instead threw the industry a curveball by requiring mandatory liquidity fees for institutional prime and institutional tax-exempt money...more

ESG and the Sustainable Economy Handbook - Overview

Environmental, social, and governance (ESG) and the sustainable economy are concepts that often overlap and frequently intertwine. Whether viewed separately or together, they have significantly changed global investing and...more

A Fund By Any Other Name: SEC Proposes Names Rule Amendments

I. SUMMARY - On 25 May 2022, the U.S. Securities and Exchange Commission (the SEC) proposed amendments (the Proposed Amendments) to Rule 35d-1 (the Names Rule) under the Investment Company Act of 1940, as amended in its...more

Proposed Money Market Fund Reforms Related to Negative Interest Rates Favor Conversion to Floating NAV and Prohibit Other...

On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which governs the structure and...more

ESG and the Sustainable Economy Handbook - Perspectives in ESG and Sustainable Investment

Environmental, social, and governance (ESG) and the sustainable economy are concepts that often overlap and frequently intertwine. Whether viewed separately or together, they have significantly changed global investing and...more

SEC Proposes Swing Pricing for Institutional Money Market Funds

SECTIONS - I. Introduction - II. Key Requirements for Swing Factor Implementation - III. When a Swing Factor Must Be Applied - IV. Calculation of the Swing Factor - V. The President’s Working Group 2020 White Paper and Prior...more

SEC Proposes Another Round of Money Market Fund Reforms

I. EXECUTIVE SUMMARY - On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which...more

Session I - Industry Regulatory Developments: 2019 Boston Investment Management Conference

AGENDA - - Liquidity Rule Implementation - ETFs: Final Rule Update and Active NonTransparent ETF Developments - Fund of Funds Rule Proposal - Board Outreach and Fund Governance Update - SEC Examination Update,...more

Saving Trees: SEC Allows Notice & Access Delivery of Shareholder Reports

On June 4, 2018, the Securities and Exchange Commission (the “SEC”) voted to adopt new Rule 30e-3 (the “Rule”) under the Investment Company Act of 1940, as amended (the “1940 Act”)....more

Click-Here for Your Fund Report: SEC Endorses Web-Delivery and Asks for Comments

A. Key Takeaways - On June 4, 2018, the Securities and Exchange Commission (“SEC”) adopted Rule 30e-3 (the “Rule”) to provide mutual funds, exchange-traded funds, closed-end funds and certain registered unit investment trusts...more

FINRA Issues Interpretive Guidance on Related Performance in Institutional Communications

On June 9, 2017, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued an interpretive letter (the “Letter”) permitting the use of Related Performance Information (as defined below) in continuously offered...more

Ninth Circuit Opinion May Open Litigation Doors Most Thought Closed

A recent Ninth Circuit Court of Appeals opinion charts potential new pathways for claims for damages resulting from portfolio losses by mutual fund shareholders against both a fund’s trustees and its investment adviser....more

Removal of Credit Ratings References

On July 23, 2014, in connection with the adoption of final rules governing the structure and operation of money market funds, the Securities and Exchange Commission (SEC) re-proposed amendments to Rule 2a-7 to implement...more

Summary of New Money Market Fund Rules Adopted by the SEC

On July 23, 2014, the Securities and Exchange Commission (the SEC) adopted final rules governing the structure and operation of money market funds, in a release adopting amendments to Rule 2a-7 under the Investment Company...more

SEC Adopts Floating NAV and Liquidity Fees/Redemption Gates Rules for Money Funds

On July 23, 2014, the Securities and Exchange Commission (the SEC) adopted final rules governing the structure and operation of money market funds. These rules are discussed in a release adopting amendments to Rule 2a-7 under...more

SEC Proposes Major Revisions to Money Market Fund Rules

On June 5, 2013, the Securities and Exchange Commission (“SEC”) voted to release its long-awaited proposals to make significant revisions to the rules governing money market mutual funds (“money funds”), as well as to adopt...more

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