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SEC Expands Scope of Fund “Names Rule”

The Securities and Exchange Commission recently adopted significant changes to Rule 35d-1 under the Investment Company Act of 1940 (Names Rule), as well as certain forms and disclosure requirements on September 20, 2023...more

Artificial Intelligence: Legal and Regulatory Issues for Financial Institutions

Over the last six months, artificial intelligence (AI) has captured the public imagination in a way it never has before. A new generation of AI-powered language models make use of a deep learning architecture known as a...more

Tenth Circuit Affirms Another Adviser Victory in Section 36(b) Lawsuit

The U.S. Court of Appeals for the Tenth Circuit has affirmed the lower court’s trial ruling in the Section 36(b) lawsuit, Obeslo v. Great-West Capital Management, LLC et al.1 The ruling comes at the tail end of a wave of...more

SEC Updates and Extends Its Targeted Actions to Assist Funds and Advisers in Light of COVID-19 Coronavirus Pandemic

On March 25, 2020, the Securities and Exchange Commission issued two orders updating and extending relief previously provided to registered funds and investment advisers whose operations may be affected by the COVID-19...more

Federal Banking Agencies Provide Temporary Relief from Compliance with Regulation O for Investment Advisers to Large Fund...

The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (Federal Banking Agencies) on December 27, 2019 provided temporary relief from...more

SEC Staff Issues No-Action Letter on Hiring Affiliated Sub-Advisers without Shareholder Approval

The staff of the Division of Investment Management of the Securities and Exchange Commission (Staff) issued a no-action letter on July 9, 2019 regarding multi-manager exemptive relief for registered open-ended investment...more

SEC Staff Issues No-Action Relief on Auditor Independence and the “Loan Provision”

The U.S. Securities and Exchange Commission’s Division of Investment Management (the “SEC Staff”) last night issued a no-action letter (the “Relief”) to Fidelity Management and Research Company that provides guidance to...more

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