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U.S. Money Market Fund Reform: Diversification, Stress Testing and Disclosure Compliance Deadline Quickly Approaching; SEC Staff...

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

Financial Services Quarterly Report - Fourth Quarter 2015: Is the U.S. SEC IM Guidance Update Initiative Becoming a Thing of the...

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

SEC Amends Rule 2a-7 to Eliminate References to NRSRO Ratings and to Revise Issuer Diversification Requirements

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

SEC Proposes to Amend Form ADV and Investment Adviser Recordkeeping Rules

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

U.S. SEC Approves Proposal to Modernize Investment Company Reporting Regime

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

SEC Staff Issues Money Market Fund Reform Frequently Asked Questions

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

U.S. Money Market Fund Reform: Form N-CR and Related Website Disclosure Compliance Deadline Quickly Approaching

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

U.S. SEC Approves Proposals to Modernize Reporting Requirements for Registered Investment Companies and Registered Investment...

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

The U.S. Securities and Exchange Commission Approves Amendments to Rules Governing Money Market Funds: Implications for Boards

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

Money Market Funds - Focus Shifts to Europe

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

U.S. SEC Approves Sweeping Amendments to Rules Governing Money Market Funds

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

SEC Approves Amendments to Rules Governing Money Market Funds

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 U.S. Supreme Court Extends Sarbanes-Oxley Whistleblower Protections to Employees of Mutual Fund Investment Advisers and Other...

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

SEC’s Division of Investment Management Issues Recommendations for Funds and Fund Advisers in Light of Reduced Market-Making...

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

SEC Charges an Investment Adviser and a Portfolio Manager with Fraud and Causing a Money Market Fund to Violate Rule 2a-7

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

Financial Services Quarterly Report - Third Quarter 2013: U.S. SEC’s Proposal to Amend Rules Governing Money Market Funds:...

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

IRS Proposes De Minimis Exception to Wash Sale Rules in Connection with SEC Money Market Fund Floating NAV Proposal

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

SEC Proposes Sweeping Amendments to Rules Governing Money Market Funds

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

SEC Proposes Amendments to Rules Governing Money Market Funds

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

The Debate Continues – U.S. Money Market Fund Update

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

IOSCO and FSB Recommend Additional Money Market Fund Reform, Putting International Pressure on the SEC to Take Action

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

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