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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

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

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 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

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