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SEC Extends Compliance Period for the Amended Names Rule

On 14 March 2025, the Securities Exchange Commission (SEC) extended the compliance dates for the amendments to Rule 35d-1 (Amended Names Rule) under the Investment Company Act of 1940, as amended (1940 Act), by six months....more

Asset Management Regulatory Year in Review 2024

2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more

Checked Swing—SEC Does Not Adopt "Swing Pricing" or a "Hard Close" for Now, but Only Provides Liquidity Guidance and Amendments to...

EXECUTIVE SUMMARY On 28 August, 2024, the Securities and Exchange Commission (SEC) adopted amendments to reporting forms for registered investment companies (funds) that will (1) require funds to file monthly (rather than...more

A Deep Dive into Money Market Fund Liquidity Fees

Executive Summary - On 12 July 2023, the Securities and Exchange Commission (the SEC) adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Final Rule), which governs the...more

Out With the Old, in With the New – SEC Scraps Swing Pricing Proposal, Removes Redemption Gates, and Mandates Liquidity Fees for...

In a surprising change, the SEC heeded the cacophony of opposition to swing pricing, but instead threw the industry a curveball by requiring mandatory liquidity fees for institutional prime and institutional tax-exempt money...more

ESG and the Sustainable Economy Handbook - Overview

Environmental, social, and governance (ESG) and the sustainable economy are concepts that often overlap and frequently intertwine. Whether viewed separately or together, they have significantly changed global investing and...more

The SEC's New Rule Demonstrates That It Believes Shareholder Reports, Like Clothes, Should Be Tailored to You

On 26 October 2022, the Securities and Exchange Commission (SEC) adopted final rules and form amendments (the Final Rules) representing significant reforms to the content and delivery of shareholder reports for open-end...more

SEC Finalizes Major Changes to Shareholder Report Disclosure Scheme and Investment Company Advertisement Rules

On 26 October 2022, the Securities and Exchange Commission (SEC) adopted final rule and form amendments (the Final Rules) representing major reforms to: 1) shareholder reports for open-end mutual funds and exchange-traded...more

Tailored Shareholder Reports and Revised Advertisement Fee Disclosure for Registered Investment Companies

The U.S. Securities and Exchange Commission (SEC) voted unanimously on Wednesday 26 October 2022 at an open meeting to adopt a new approach to shareholder and investor communications by registered open-end funds and...more

Proposed Money Market Fund Reforms Related to Negative Interest Rates Favor Conversion to Floating NAV and Prohibit Other...

On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which governs the structure and...more

ESG and the Sustainable Economy Handbook - Perspectives in ESG and Sustainable Investment

Environmental, social, and governance (ESG) and the sustainable economy are concepts that often overlap and frequently intertwine. Whether viewed separately or together, they have significantly changed global investing and...more

SEC Proposes Swing Pricing for Institutional Money Market Funds

SECTIONS - I. Introduction - II. Key Requirements for Swing Factor Implementation - III. When a Swing Factor Must Be Applied - IV. Calculation of the Swing Factor - V. The President’s Working Group 2020 White Paper and Prior...more

SEC Proposes Another Round of Money Market Fund Reforms

I. EXECUTIVE SUMMARY - On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which...more

Fund of Funds Rule Adoption—A Deeper Dive Into the Impact of Rule 12d1-4 on Closed-End Funds and Business Development Companies

I. INTRODUCTION - On October 7, 2020, the Securities and Exchange Commission (SEC) adopted new rule 12d1-4 (Rule 12d1-4) and related amendments under the Investment Company Act of 1940 (as amended, the 1940 Act) in an effort...more

SEC Adopts New Rule 12d1-4 Overhauling Fund of Funds Arrangements--Are You Ready?

I. EXECUTIVE SUMMARY - On 7 October 2020, the Securities and Exchange Commission (the SEC) adopted new rule 12d1-4 (Rule 12d1-4) and related amendments under the Investment Company Act of 1940 (the 1940 Act) that it believes...more

SEC Proposes Major Changes to Prospectus and Shareholder Report Disclosure Scheme

I. INTRODUCTION AND SUMMARY - The Securities and Exchange Commission (SEC) has proposed a bold new approach to shareholder and investor communications by investment companies registered on Form N-1A under the Investment...more

Closed-End Fund and BDC Offering, Filing and Disclosure Changes: Some Benefits, Some Burdens

On April 8, 2020, the Securities and Exchange Commission (the “SEC”) adopted final rule and form amendments (the “Final Rules”) that modify the registration, offering, and communications processes currently used by registered...more

COVID-19: Emergency SEC Staff Action Allows Conditional Sale to Affiliates of Portfolio Debt Securities Held by Open-End Funds

On March 26, 2020, the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) took a substantial step in recognition of the significant securities market disruptions related to COVID-19 and granted...more

COVID-19: Rapid SEC Action on Open-End Fund Borrowing for Liquidity

On March 23, 2020, the Securities and Exchange Commission released an order (the “Order”) relaxing interfund lending rules for open-end funds impacted by recent market events associated with the pandemic outbreak of COVID-19....more

COVID-19: SEC Provides Guidance to Funds Conducting Shareholder Meetings

On March 13, 2020, the staff of the Division of Corporation Finance and the Division of Investment Management of the U.S. Securities and Exchange Commission (“SEC”) issued guidance to provide flexibility and assist issuers...more

Session III - Closed-End and Alternative Strategy Funds and BDCs: 2019 Boston Investment Management Conference

WHY CLOSED-END FUNDS, ALTERNATIVE STRATEGY FUNDS, AND BDCS? - Many advisers recommend alternative assets or alternative strategies and structures as part of an investor’s diversified investment portfolio - For...more

Offering Reforms or Burdensome Regulations? It Depends!

SEC Proposes Reforms for Registration Process of Closed-End Funds and Business Development Companies - On March 20, 2019, the Securities and Exchange Commission (“SEC”) proposed several rules (the “Proposed Rules”) that...more

Saving Trees: SEC Allows Notice & Access Delivery of Shareholder Reports

On June 4, 2018, the Securities and Exchange Commission (the “SEC”) voted to adopt new Rule 30e-3 (the “Rule”) under the Investment Company Act of 1940, as amended (the “1940 Act”)....more

Click-Here for Your Fund Report: SEC Endorses Web-Delivery and Asks for Comments

A. Key Takeaways - On June 4, 2018, the Securities and Exchange Commission (“SEC”) adopted Rule 30e-3 (the “Rule”) to provide mutual funds, exchange-traded funds, closed-end funds and certain registered unit investment trusts...more

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