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Mutual Funds Should Consider Deferring Form 24F-2 Filings in Light of Substantial Decrease in SEC Registration Fee Rate

Securities registration fee rates for mutual funds registered under the Investment Company Act of 1940 (the “1940 Act”) will be decreasing nearly 10%, effective October 1, 2014. ...more

SEC Announces Exam Initiative Targeting Newly Registered Municipal Advisors

The SEC announced an initiative in which its Office of Compliance Inspections and Examinations (OCIE) plans to examine a significant percentage of newly registered municipal advisors over the next two years using an approach...more

SEC Integrates Two Exempt Reporting Advisers to Determine Advisers Act Registration Status

The SEC settled public administrative proceedings against TL Ventures Inc., a venture capital fund adviser (the “VC Fund Adviser”) and Penn Mezzanine Partners Management, L.P. (the “Private Fund Adviser” and with the VC Fund...more

CFTC Announces Streamlined Approach for Seeking Relief from Registration for Delegating Commodity Pool Operators

The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) announced a streamlined approach for requesting relief from the commodity pool operator (“CPO”) registration requirement for a CPO that delegates...more

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

House Passes Bill to Increase Shareholder Count Thresholds Triggering Securities Exchange Act Registration/Deregistration...

On January 14, 2014, the House of Representatives passed H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (the “Act”), which would increase the number of shareholders that trigger registration and...more

SEC Issues Frequently Asked Questions Regarding Municipal Advisor Registration Rules

The SEC’s Office of Municipal Securities has released a list of frequently asked questions and answers (the “FAQ”) that presents its views regarding various aspects of the SEC’s municipal advisor registration rules (the...more

NFA Issues Guidance on Annual Affirmation Requirement for Entities Operating Under An Exemption or Exclusion from CPO or CTA...

The National Futures Association (the “NFA”) has issued guidance reminding market participants of CFTC regulations that require any person claiming an exemption or exclusion under CFTC Regulation 4.5, 4.13(a)(1), 4.13 (a)(2),...more

Private Fund Adviser Receives Exemptive Relief from Two-Year Compensation Ban under Pay-to-Play Rule Triggered by Contribution to...

An SEC-registered adviser (the “Adviser”) was granted exemptive relief pursuant to Rule 206(4)-5 (the “Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) from the Rule’s two-year prohibition on receiving...more

CFTC Proposes Rule to Require All Registered Introducing Brokers, Commodity Pool Operators, and Commodity Trading Advisors to be...

The CFTC has proposed a rule that would require all registered introducing brokers (“IBs”), commodity pool operators (“CPOs”), and commodity trading advisors (“CTAs”) to be members of a registered futures association (“RFA”)....more

SEC and FINRA Rule Proposals Take Next Steps Towards Fulfilling JOBS Act Crowdfunding Mandate

The SEC issued a rule proposal designed to fulfill a mandate under the 2012 Jumpstart Our Business Startups (“JOBS”) Act to adopt rules that implement changes to the federal securities laws under the JOBS Act that permit...more

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