On October 13, 2023, the SEC adopted Rule 13f-2 and related Form SHO pursuant to the Securities Exchange Act of 1934 (the “Exchange Act”). Rule 13f-2 seeks to address Congress’ directive under Section 929X of the Dodd-Frank...more
David W. Grim, Director of the SEC’s Division of Investment Management (the “Division”), recently noted in testimony before a U.S. House of Representatives subcommittee that the Division is developing new rule recommendations...more
Investment advisers with clients (including funds or separate accounts) that use swaps are reminded to have such clients sign up to the ISDA March 2013 DF Protocol (the “March DF Protocol”) by July 1, 2013....more
Managers Who Use Swaps Should Act Now -
Managers of funds and separately managed accounts that use swaps are reminded that they (or their clients) must complete the DF Protocol Adherence Letter and DF Protocol...more