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Reminder for all 13F Filers: Form N-PX is due this month - by August 31, 2024

Mutual funds and other registered investment companies have long had an obligation to file Form N-PX, giving the SEC and the public access to how a fund voted proxies on an annual basis. New Rule 14Ad-1 under the Securities...more

CFTC Year in Review: 23 Takeaways From 2023 and Predictions for 2024

At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more

CFTC Proposes Amendments to CPO, CTA Regulations

The Commodity Futures Trading Commission (CFTC or Commission) recently proposed amendments to CFTC Regulation 4.7 (the Proposed Rule) that would impact long-standing exemptions from certain compliance requirements for...more

SEC Guidance for Private Fund Advisers

On June 23, 2020, the US Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a risk alert (Risk Alert) describing common deficiencies and compliance issues for...more

COVID-19: SEC Grants Temporary Relief to Mutual Funds from Borrowing and Lending Restrictions

On March 23, 2020, the SEC issued an order (the “Order”) granting registered open-end funds and insurance company variable annuity separate accounts expanded capability to borrow from their affiliates to satisfy redemption...more

COVID-19/Market Disruption Update for Investment Managers

The outbreak of the coronavirus (COVID-19) continues to impact markets and business operations in unprecedented ways, which presents risks and opportunities to investment advisers and fund managers. This client alert...more

SEC Enforcement Alert: D.C. Circuit Rules Negligent Conduct Is Not “Willful”

On April 30, 2019, the D.C. Circuit issued an important decision in Robare Group, Ltd. v. SEC, Slip Op. No. 16-1453, which rejected the long-standing approach of the Securities and Exchange Commission (Commission or SEC) that...more

Mutual Fund Sponsors Beware: Recent SEC Staff Guidance could Result in Lapse in Registration

In a footnote to an April 2, 2019 SEC Staff guidance, the Staff requested that mutual funds file a delaying amendment to postpone the effective date of their registration statements if a fund is unable to submit responses to...more

OCIE Risk Alert on Cash Solicitation Rule

On October 31, 2018, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert regarding compliance deficiencies observed in connection with Rule...more

SEC Proposes New Framework for Regulating Funds’ Use of Derivatives and Leverage

On December 11, 2015, the Securities and Exchange Commission (Commission) proposed a rule that, if adopted, would rescind nearly 30 years of Commission and staff guidance that is currently relied upon by most mutual funds,...more

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