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SEC Staff Reverses Position on State Control Share Statutes for Closed-End Funds

On May 27, 2020, the staff of the SEC’s Division of Investment Management withdrew previously issued guidance addressing the intersection between state control share acquisition statutes (control share statutes) and the...more

Special Issue on COVID-19 Related Developments - Investment Services Regulatory Update - April 2020

COVID-19 RELATED DEVELOPMENTS – SPECIAL REGULATORY UPDATE – New SEC Guidance on PPP Loans, Form ADV Brochure Delivery and the Custody Rule - On April 27, 2020, the staff of the Securities and Exchange Commission (the...more

COVID-19 Update – SEC Staff Issues Guidance for Conducting Annual Meetings

On March 13, 2020, the staff of the SEC’s Division of Investment Management and Division of Corporation Finance issued guidance in response to various inquiries from issuers and shareholders regarding compliance with the...more

Investment Services Regulatory Update - February 2020

New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – Agencies Propose Volcker Rule Amendments Relating to Covered Funds – On January 30, 2020, the Federal Reserve Board, FDIC, OCC, SEC and CFTC proposed...more

Investment Services Regulatory Update - December 2019

New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes Rule Changes for Proxy Advisory Firms – On November 5, 2019, the SEC issued a release proposing amendments to the federal proxy rules...more

SEC Staff Updates Prior Accounting Guidance and Publishes Accounting Matters Bibliography

On November 27, 2019, the Chief Accountant of the SEC’s Division of Investment Management issued a “Dear CFO” letter—the first in nearly 20 years—to update certain accounting guidance appearing in prior Dear CFO letters that...more

SEC Issues FAQs on Adviser Conflict Disclosure Practices

On October 18, 2019, the SEC’s Division of Investment Management issued guidance in the form of Frequently Asked Questions that address certain matters regarding the disclosure of conflicts of interest involving the receipt...more

FINRA Issues Supplemental Guidance on Giving Credit for Extraordinary Cooperation

On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which FINRA awards credit for providing "extraordinary cooperation" during an...more

Investment Services Regulatory Update - December 2017

New Rules, Proposed Rules, Guidance and Alerts - NEW RULES - SEC Delays Form N-PORT EDGAR Filing Requirement by Nine Months - On December 8, 2017, the SEC adopted a temporary rule (the Temporary Rule) delaying by...more

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