The April 14, 2016 compliance date for certain new money market fund (money funds) requirements adopted by the U.S. Securities and Exchange Commission (SEC) is quickly approaching. In particular, money funds will be required...more
Over the past three years, the Division of Investment Management (Division) of the U.S. Securities and Exchange Commission (Commission) has provided informal guidance and interpretations regarding issues of relevance to the...more
The U.S. Securities and Exchange Commission (SEC) recently adopted amendments (Amendments) to remove references to credit ratings in Rule 2a-7 under the Investment Company Act of 1940, as amended (1940 Act), the primary rule...more
11/10/2015
/ ABS ,
Asset Diversification ,
Bonds ,
Diversification Requirements ,
Dodd-Frank ,
Investment Company Act of 1940 ,
Money Market Funds ,
Municipal Securities Issuers ,
NRSRO ,
Repurchases ,
Rule 2a-7 ,
Securities and Exchange Commission (SEC)
The U.S. Securities and Exchange Commission (SEC or Commission) recently proposed amendments to Form ADV and to Rule 204-2 (Recordkeeping Rule) and other rules under the Investment Advisers Act of 1940, as amended (Advisers...more
7/17/2015
/ CCO ,
Disclosure Requirements ,
Dodd-Frank ,
Form ADV ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
RAUM ,
Recordkeeping Requirements ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Social Media ,
Umbrella Registration
The U.S. Securities and Exchange Commission (SEC or Commission) unanimously approved a proposal (Proposal) to modernize the reporting of information provided by registered investment companies (funds). Guided by the recent...more
6/17/2015
/ Amended Regulation ,
Asset Management ,
Compliance ,
Derivatives ,
EDGAR ,
Federal Register ,
Form N-CEN ,
Form N-PORT ,
Form N-SAR ,
Investment Companies ,
Investment Company Act of 1940 ,
Legal Entity Identifiers ,
Mary Jo White ,
Money Market Funds ,
Private Funds ,
Registered Funds ,
Regulation S-X ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Shareholders ,
Small Business Investment Company
The Staff of the Division of Investment Management (Staff) of the U.S. Securities and Exchange Commission (SEC or Commission) has published responses to frequently asked questions (FAQs) regarding the SEC’s 2014 amendments...more
6/17/2015
/ Amortization ,
Capital Contributions ,
Disclosure Requirements ,
Division of Investment Management ,
Floating NAV ,
Fund Managers ,
Investment Companies ,
Liquidity Fees ,
Money Market Funds ,
NAV ,
New Amendments ,
Redemption Gates ,
Reorganizations ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Seed Financing ,
Websites
The July 14, 2015 compliance date for certain new money market fund reporting and disclosure requirements adopted by the U.S. Securities and Exchange Commission (SEC) is quickly approaching. In particular, money market funds...more
The U.S. Securities and Exchange Commission (SEC) today unanimously approved proposals (Proposals) to modernize the reporting of information provided by registered investment companies (funds) and registered investment...more
5/22/2015
/ Annual Reports ,
Financial Statements ,
Form ADV ,
Form N-CEN ,
Form N-PORT ,
Form N-SAR ,
Form PF ,
Investment Adviser ,
Investment Companies ,
Private Funds ,
Public Disclosure ,
Regulation S-X ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
The U.S. Securities and Exchange Commission (SEC) has approved sweeping amendments to Rule 2a-7 under the Investment Company Act of 1940 and other rules governing the operations of money market funds (money funds)...more
Following the adoption by the U.S. Securities and Exchange Commission (“SEC”) of amendments to the rules governing U.S. money market funds (“MMFs”), the focus is shifting to Europe. In fact, the prospects for sensible MMF...more
The U.S. Securities and Exchange Commission (SEC or Commission) on July 23, 2014 approved, by a vote of 3- 2, sweeping amendments to Rule 2a - 7 and other rules that govern money market funds (money funds) under the...more
Yesterday, the U.S. Securities and Exchange Commission (“SEC”), by a vote of 3 to 2, approved amendments to Rule 2a-7 and other rules that govern money market funds under the Investment Company Act of 1940 (the “Amendments”)....more
The Supreme Court of the United States on March 4, 2014 held that employees of a privately-held mutual fund investment adviser are protected under a whistleblower provision enacted as part of the Sarbanes-Oxley Act of 2002...more
The Division of Investment Management (“Division”) of the U.S. Securities and Exchange Commission (“SEC”) recently published guidance (“Guidance”) addressing steps that funds and fund advisers should consider in light of...more
2/14/2014
/ Banking Sector ,
Broker-Dealer ,
Federal Reserve ,
Fixed Income Investments ,
Internal Revenue Code (IRC) ,
Investment Adviser ,
Investment Funds ,
Investment Management ,
Market Making ,
Market Risk Capital Rule ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
This OnPoint describes the role of the SEC’s Division of Investment Management (Division) in uncovering the alleged fraud through an analytical review of the Fund’s performance data and portfolio information. It then...more
12/19/2013
/ Enforcement ,
Enforcement Actions ,
Fraud ,
Fund Managers ,
Investment Fraud ,
Investor Protection ,
OCIE ,
Portfolio Managers ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Fraud
The U.S. Securities and Exchange Commission (“SEC”) has proposed sweeping amendments to Rule 2a-7 under the Investment Company Act of 1940 (“1940 Act”) and other rules relating to money market funds (“money funds”).1 The...more
The U.S. Internal Revenue Service (IRS) has proposed a new Revenue Procedure (Proposed Revenue Procedure) regarding the application of the wash sale rules under Section 1091 of the U.S. Internal Revenue Code (Code) to...more
The U.S. Securities and Exchange Commission (SEC or Commission) on June 5, 2013 proposed for public comment sweeping amendments to Rule 2a-7 under the Investment Company Act of 1940 and other rules relating to money market...more
On June 5, 2013, the U.S. Securities and Exchange Commission (SEC) unanimously proposed for public comment two alternatives for amending Rule 2a-7 and other rules that govern money market funds under the Investment Company...more
Since the U.S. Financial Stability Oversight Council (“FSOC”) issued proposed recommendations to the U.S. Securities and Exchange Commission (“SEC”) regarding additional reforms to money market fund (“money fund”) regulation...more
Introduction -
The International Organization of Securities Commissions (IOSCO), an international organization of securities regulators, recently published its “Policy Recommendations for Money Market Funds” (Final...more