OVERVIEW OF THE ETF RULE -
- On September 25, 2019, the SEC approved Rule 6c-11 under the 1940 Act (the “ETF Rule”) and related amendments to Form N-1A
- The ETF Rule will rescind previously-issued exemptive orders of...more
LEGISLATIVE POLICY -
“In the exhaustive study of the industry which preceded passage of the [Investment Company] Act it was found that, in many instances, investment companies had been operated in the interests of their...more
Executive Summary - In a significant step toward improving variable insurance product (“VIP”) disclosure, the U.S. Securities and Exchange Commission (“SEC”), on October 30, 2018, proposed a new rule (the “Summary Prospectus...more
On March 8, 2017, the staff of the Securities and Exchange Commission (“SEC”) granted no-action relief that potentially will permit global investment management firms to offer U.S. registered open-end management investment...more
The Commodity Futures Trading Commission (CFTC) recently approved the National Futures Association’s Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49, entitled Information Systems Security Programs (the...more
On September 15, 2015, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “2015 Risk Alert”) that announced its second round of cybersecurity...more
9/24/2015
/ Best Practices ,
Broker-Dealer ,
Compliance ,
Cybersecurity ,
Data Loss Prevention ,
Data Protection ,
Data Security ,
Financial Institutions ,
Financial Markets ,
Incident Response Plans ,
Investment Adviser ,
OCIE ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
Securities Exchanges
The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more
9/10/2015
/ CFTC ,
Commodity Broker ,
Commodity Pool ,
Compliance ,
CPOs ,
Cybersecurity ,
Data Protection ,
Data Security ,
Data Storage Providers ,
Dealers ,
Financial Markets ,
Foreign Exchanges ,
Information Systems Security Program (ISSP) ,
Interpretive Rule ,
Investment Companies ,
Investment Company Act of 1940 ,
Investment Management ,
Mobile Device Management ,
Mutual Funds ,
National Futures Association ,
NIST ,
Personally Identifiable Information ,
Swap Dealers ,
Swaps ,
Third-Party Service Provider
On February 3, 2015, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “2015 Risk Alert”) with summary observations from its recently...more
2/16/2015
/ Broker-Dealer ,
Compliance ,
Cyber Attacks ,
Cybersecurity ,
Data Protection ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Investment Adviser ,
OCIE ,
Popular ,
Risk Management ,
Securities and Exchange Commission (SEC)
On August 13, 2013, the Commodity Futures Trading Commission (“CFTC”) adopted long-awaited harmonization rules (“Harmonization Rules”) for operators of registered investment companies (“Registered Funds”) that are subject to...more