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SEC Sanctions Robo Adviser for Inadequate Conflicts Disclosures, Failure to Consider Tax Impact of Proprietary ETFs

Not long after we released our recent alert titled SEC Continues Focus on Conflicts Disclosures in Enforcement Actions Totaling $106 Million in Fines and Disgorgement, the U.S. Securities and Exchange Commission (the...more

SEC Division of Examinations Releases 2021 Examination Priorities

Each year, the SEC’s Division of Examinations (f.k.a. OCIE) (the “Division”) releases its priorities for the upcoming year, providing SEC registrants with a helpful tool to assist in managing, reviewing, and updating their...more

SEC Adopts Derivatives Overhaul for Funds

On October 28, 2020, the Securities and Exchange Commission (“SEC”) finalized Rule 18f-4 under the Investment Company Act, a new rule designed to provide an updated and comprehensive framework for the use of derivatives by...more

SEC Issues Final ETF Rule and Amends Form N-1A

The SEC recently adopted a final rule (the “ETF Rule”) designed to modernize the registration of exchange-traded funds (“ETFs”). Since 1992, an ETF coming to market has required an exemptive relief order from the SEC to...more

SEC Loosens In Person Voting Requirements for Mutual Fund and other Registered Investment Company

As just about everyone who operates in the mutual fund, closed-end fund or exchange-traded fund (ETF) industries knows, the Investment Company Act of 1940, as amended (the “1940 Act”), requires certain key registered...more

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