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SEC Settles Enforcement Proceedings Against Five Advisers for Alleged Marketing Rule Violations

On April 12, 2024, the SEC announced the settlement of administrative proceedings brought against five registered investment advisers for alleged violations of Rule 206(4)-1 under the Investment Advisers Act of 1940, known as...more

SEC Staff Risk Alert Focuses on Preparations for T+1 Settlement

On March 27, 2024, the staff of the SEC’s Division of Examinations issued a risk alert highlighting its intent to focus, during examinations and outreach on market participants’ preparations for the shortening of the standard...more

SEC Settles Charges Against Advisers for Alleged False and Misleading Statements About Their Use of Artificial Intelligence

On March 18, 2024, the SEC announced that it had settled charges against two investment advisers for allegedly making false and misleading statements about their use of artificial intelligence (AI) in providing advisory...more

SEC Adopts Rules to Enhance and Standardize Climate-Related Disclosures

On March 6, 2024, the SEC voted 3-2 to adopt final rules requiring public companies, excluding investment companies but not excluding business development companies, to disclose climate-related information in their...more

D.C. District Court Overturns SEC Proxy Advisor Rule, Holding Proxy Voting Advice Is Not Solicitation

On February 23, 2024, the U.S. District Court for the District of Columbia, in a case dating back to 2019, vacated certain SEC rule amendments regarding proxy advisory firms, holding that “the SEC acted contrary to law and in...more

SEC Adopts Amendments to Narrow the Internet Adviser Exemption

On March 27, 2024, the SEC adopted amendments to Rule 203A-2(e) (the Internet Adviser Exemption) under the Investment Advisers Act of 1940 to narrow the types of small investment advisers that can register with the SEC in...more

Second Circuit Affirms Lower Court Decision Regarding Closed-End Fund Control Share Bylaw Provision

The U.S. Court of Appeals for the Second Circuit upheld a ruling of the U.S. District Court for the Southern District of New York that invalidates control share bylaw provisions adopted by certain closed-end funds organized...more

SEC Issues New Strategic Plan for Diversity, Equity, Inclusion, and Accessibility

On September 18, 2023, the SEC announced the agency’s Diversity, Equity, Inclusion, and Accessibility (DEIA) Strategic Plan for fiscal years 2023 through 2026. The SEC stated that a commitment to DEIA is critical to...more

SEC Staff Issues Risk Alert Regarding the Selection and Scope of Adviser Examinations

On September 6, 2023, the staff of the SEC’s Division of Examinations issued a risk alert describing the staff’s risk-based approach in selecting registered investment advisers to examine and in determining the scope of areas...more

SEC Settles Enforcement Proceedings Against Nine Advisers for Alleged Marketing Rule Violations

On September 11, 2023, the SEC announced the settlement of administrative proceedings brought against nine registered investment advisers for disseminating hypothetical performance returns on their public websites without...more

SEC Proposes Significant Form and Rule Amendments for the Registration of Index-Linked Annuities

On September 29, 2023, the SEC proposed significant form and rule amendments to establish a tailored registration form for index-linked annuities, as directed by Congress under the Registered Index-Linked Annuities Act of...more

SEC Adopts Amendments to Fund Names Rule, Broadening the Scope of Funds that Must Comply

On September 20, 2023, the SEC adopted amendments to the investment company names rule, Rule 35d-1 under the Investment Company Act of 1940. According to SEC estimates, the amendments will bring approximately 2,200 funds that...more

SEC Staff Issues Risk Alert Regarding Observations from Anti Money Laundering Compliance Examinations of Broker Dealers

On July 31, 2023, the SEC’s Division of Examinations issued a risk alert presenting observations regarding deficiencies with respect to compliance with key anti-money laundering (AML) requirements observed in compliance...more

SEC Proposes New Requirements to Address Conflicts of Interest in the Use of Artificial Intelligence and Similar Technologies

On July 26, 2023, the SEC issued proposed rules under the Securities Exchange Act of 1934 and the Investment Advisers Act of 1940 to address conflicts of interest that the SEC believes are associated with the use by...more

SEC Proposes Amendments to the Internet Adviser Exemption

On July 26, 2023, the SEC issued proposed rules under the Investment Advisers Act of 1940 to narrow the types of smaller investment advisers that can register with the SEC in reliance on the Internet adviser exemption....more

SEC Adopts Significant Money Market Fund Reforms and Amended Form PF Reporting Requirements for Private Liquidity Fund Advisers

On July 12, 2023, in a 3-2 vote, the SEC adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, representing the SEC’s latest reforms of the rules governing money market funds in its effort to improve their...more

Investment Services Regulatory Update - June 2020

New Rules, Proposed Rules, Guidance and Alerts - NEW RULES - SEC Amends Financial Reporting Rules for Investment Company Business Combination Transactions - On May 20, 2020, the SEC adopted amendments to the...more

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

SEC Amends Financial Reporting Rules for Investment Company Business Combination Transactions

On May 20, 2020, the SEC adopted amendments to the financial statement disclosure requirements under Regulation S-X related to acquisitions and dispositions involving investment companies. First, the amendments streamline...more

SEC Extends Relief from 1940 Act In-Person Voting Requirements

As previously reported, in March 2020, the SEC issued exemptive orders providing relief from certain provisions of the Investment Company Act of 1940 to registered funds in light of the outbreak of coronavirus disease 2019...more

SEC Staff Issues No-Action Letter Regarding Fund Participation in the Federal Reserve Board’s 2020 Term Asset-Backed Loan Facility...

On May 27, 2020, the SEC staff issued a no-action letter to the Investment Company Institute (ICI) and the Securities Industry and Financial Markets Association (SIFMA) permitting registered funds to participate in the Term...more

SEC Chairman Confirms June 30 Compliance Date for Regulation Best Interest and Form CRS

On June 15, 2020, SEC Chairman Jay Clayton released a public statement confirming the June 30, 2020 compliance date for Regulation Best Interest (Reg BI) and Form CRS. Reg BI establishes a new standard of conduct for...more

Investment Services Regulatory Update - May 2020

New Rules, Proposed Rules, Guidance and Alerts - PROPOSED RULES - SEC Proposes New Fair Valuation Framework for Registered Funds - Under the Investment Company Act of 1940, securities held by a fund for which...more

SEC Proposes New Fair Valuation Framework for Registered Funds

Under the Investment Company Act of 1940, securities held by a fund for which market quotations are readily available are to be priced at current market value, and securities for which market quotations are not readily...more

COVID-19 ALERT: Special Considerations for Registered Closed-End Funds

This Alert focuses on special considerations for closed-end funds registered under the Investment Company Act of 1940, as amended (the ‘1940 Act’), arising from COVID-19 (coronavirus) and related regulatory relief of interest...more

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