Brief Overview - On 27 March 2024, the US Securities and Exchange Commission (SEC) adopted amendments (the Amendments) to Rule 203A-2(e) under the Investment Advisers Act of 1940 (Advisers Act). Rule 203A-2(e) is commonly...more
Executive Summary - Newly proposed rules (the Predictive Analytics Rules) will, if adopted as proposed, require broker-dealers and investment advisers (firms) to: (i) identify conflicts of interests when using certain...more
INTRODUCTION - On 26 May 2021, the Commodity Futures Trading Commission’s (CFTC or the Commission) Market Participants Division (MPD) published updated responses to frequently asked questions regarding Form CPO-PQR and CFTC...more
Introduction - On 13 April 2021, the National Futures Association (NFA) released an Interpretive Notice entitled Compliance Rule 2-50: CPO Notice Filing Requirements (Interpretive Notice)....more
On 28 October 2020, the U.S. Securities and Exchange Commission adopted Rule 18f-4 under the Investment Company Act of 1940, as amended. The rule replaces the SEC’s decades-old patchwork of guidance with a comprehensive...more
INTRODUCTION - The Commodity Futures Trading Commission (CFTC) recently voted 3–2, along party lines, to approve a final rule (Final Rule) regarding position limits for certain futures contracts and economically equivalent...more
The Commodity Futures Trading Commission (CFTC or Commission) recently held its first virtual open meeting and unanimously approved three proposed rules and two final rules. Chairman Heath Tarbert emphasized that, for the...more
INTRODUCTION - On January 30, 2020, the Commodity Futures Trading Commission (“CFTC” or “Commission”) approved a proposed rule (the “Proposed Rule”) for new and amended regulations concerning speculative position limits for...more
I. INTRODUCTION -
The Commodity Futures Trading Commission (“CFTC” or “Commission”) recently approved a proposed rule (the “Proposed Rule”) to improve the regulation of cross-border swap transactions and establish a formal...more
Introduction -
On January 31, 2019, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued an interpretive letter (the “2019 Letter”) extending previously issued guidance by permitting passively managed...more
On May 12, 2015, the Financial Industry Regulatory Authority (“FINRA”) issued an interpretive letter (the “Letter”) permitting the use of Related Performance Information (as defined below) in communications distributed solely...more