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SEC Amends Registered Fund Reporting Requirements, Issues Guidance on Liquidity Risk Management Programs

The US Securities and Exchange Commission (SEC), by a 3-2 vote, recently adopted amendments to registered fund reporting requirements on Form N-PORT and Form N-CEN and provided guidance on open-end funds’ liquidity risk...more

Names Rule Amendments Will Require Changes For Certain Funds

On September 20, 2023, in a 4-1 vote, the US Securities and Exchange Commission (SEC) adopted amendments (the Amendments) to the rule governing fund names, which impose new disclosure, compliance, reporting, and recordkeeping...more

SEC Adopts Further Money Market Fund Reforms

The US Securities and Exchange Commission (Commission) adopted amendments to the rule governing money market funds on July 12, 2023 in an attempt to address concerns about institutional prime and institutional tax-exempt...more

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

Tailoring Shareholder Reports: SEC Finalizes Amendments to Registered Fund Shareholder Reporting Requirements

The US Securities and Exchange Commission (SEC) recently finalized rule and form amendments (Adopted Rules) that require mutual funds and most exchange-traded funds (ETFs) to provide shareholders with streamlined and...more

The Name Game: SEC Proposes Expanding Scope of Registered Funds’ ‘Names Rule’

In a 3-1 vote, the US Securities and Exchange Commission on May 25 proposed amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Names Rule) that, if adopted as proposed, could cause new entrants and...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

Tax Proposals May Affect Exchange-Traded Funds

Recently proposed tax legislation, if enacted, would fundamentally alter the taxation of exchange‑traded funds. This LawFlash discusses the potential consequences of such legislation on industry participants, including retail...more

1940 Act Regulatory Checklists

Rule 12d1-4 under the Investment Company Act of 1940 permits funds to enter into “funds of funds” arrangements notwithstanding the prohibitions of Section 12(d)(1) of the Act of 1940, provided that certain conditions are met....more

SEC Modernizes Framework for Fund Valuation Practices

Financial markets and fund investment practices have changed substantially since the US Securities and Exchange Commission (SEC) last addressed fund valuation comprehensively 50 years ago. In adopting Rule 2a-5 on December 3,...more

New SEC Rule Will Regulate Registered Fund Investments in Derivatives

On October 28, 2020, the US Securities and Exchange Commission (SEC) voted 3–2 to adopt Rule 18f-4 (the Rule) under the Investment Company Act of 1940 (the Investment Company Act), which will replace decades-old SEC and staff...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 New Regulation of Fund Valuation

Under the proposal issued April 21, the SEC would substantially revise the regulation of fund valuation for the first time in 50 years and rescind much of the current guidance. ...more

COVID-19: US Regulatory Relief and Related Effects on Markets and Participants

The US Securities and Exchange Commission, Financial Industry Regulatory Authority, Commodity Futures Trading Commission, and National Futures Association have each announced temporary regulatory relief for market...more

COVID-19: SEC Staff Permits Affiliates to Purchase Debt Securities from a Mutual Fund

The staff of the US Securities and Exchange Commission (SEC) has given registered open-end management companies (mutual funds) an additional tool in the wake of the coronavirus (COVID-19) crisis to combat the potentially...more

COVID-19 Market Impact SEC Provides Short-Term Funding Affiliated Purchase Flexibility to Funds

The US Securities and Exchange Commission is providing increased flexibility to certain open-end funds and insurance company separate accounts, plus no-action relief to money market funds and their affiliates amid the...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 Proposes New Comprehensive Registered Fund of Funds Rule

The new rule would permit registered funds to invest in other registered funds beyond the limits of Section 12(d)(1) of the Investment Company Act of 1940 without the need to obtain individual exemptive orders from the US...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

SEC Proposes New ETF Rule

The new rule would permit ETFs to operate without the need to obtain individual exemptive orders from the US Securities and Exchange Commission....more

SEC Approves Generic Listing Standards for Active ETFs

New standards are expected to simplify and expedite the process of launching an actively managed ETF. On July 22, the US Securities and Exchange Commission (SEC) issued orders approving proposals by Bats BZX Exchange,...more

SEC Staff Issues No-Action Letter on Index Fund Investments in Insurance Companies and Securities Related Businesses

SEC staff expands upon prior no-action positions to permit funds that track a third-party index to invest in insurance companies and securities related businesses beyond the limitations set forth in Sections 12(d)(2) and...more

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