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SEC Staff Clarifies Position on Disaggregation for Section 13(d) and 16(a) Reporting by Certain ETF Authorized Participants

The SEC’s Division of Corporation Finance recently posted new compliance and disclosure interpretations concluding that any registered broker-dealer acting as an authorized participant (AP) for any ActiveShares...more

SEC Proposes Mandatory Swing Pricing for Mutual Funds and Revised Liquidity Requirements

On November 2, 2022, the US Securities and Exchange Commission (SEC), by a 3-2 party line vote, proposed amendments (the Proposal) to the liquidity risk management programs rule (Rule 22e-4) under the Investment Company Act...more

ETF Roundup – Issue 7 December 2021

UPDATE ON CRYPTO ASSETS IN ETFS - In 2018, the US Securities and Exchange Commission’s Division of Investment Management staff penned a letter to the Investment Company Institute and the Securities Industry and Financial...more

SEC Adopts Comprehensive Framework for Fund of Funds Arrangements

On October 7, 2020, the US Securities and Exchange Commission (SEC) adopted Rule 12d1-4 (Rule) under the Investment Company Act of 1940 (Act) and related amendments (Amendments) that are collectively designed to provide a...more

ETF Roundup – Issue 6

GENERIC LISTING STANDARDS FOR ETFS RELYING ON RULE 6C-11 APPROVED - The US Securities and Exchange Commission (SEC) has approved generic listing standards proposed by NYSE Arca, Inc., Cboe BZX Exchange, Inc., and The Nasdaq...more

SEC Proposes Requirements for Funds’ Use of Derivatives and Other Transactions - December 2019

The US Securities and Exchange Commission (SEC) proposed new rules and amendments on November 25 that establish requirements for the use of derivatives and other financial transactions by registered investment companies,...more

The New ETF Rule: Initial Impressions

The US Securities and Exchange Commission (SEC) unveiled in final form the regulatory framework that will govern the operation of most exchange-traded funds (ETFs) going forward. Rule 6c-11 (Rule) under the Investment Company...more

SEC Staff Relieves Fund Boards of Certain Compliance Determinations

In a recent no-action letter, the US Securities and Exchange Commission staff relieved fund boards of directors of the responsibility for determining compliance with key affiliated transaction exemptive rules. Boards will now...more

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