From 1 August 2024, the UK changed its rules on how payments are made for investment research. UK firms may now use bundled payments for third-party research and trading commissions, subject to certain requirements being...more
In our previous alert, Paying for Buy-Side Investment Research: Will the FCA’s Third Way Ease the US-UK Divide?, we discussed the consultation issued by the Financial Conduct Authority (FCA) on proposed rules on payment...more
On 10 April 2024, the Financial Conduct Authority (FCA) published a Consultation Paper on payment optionality for investment research (CP24/7). CP24/7 followed the UK Investment Research Review, in which recommendations were...more
The UK’s financial services regulator, the Financial Conduct Authority (FCA), has delayed the release of its policy statement setting out the final rules of the Sustainability Disclosure Requirements (SDRs), leaving asset...more
The US Securities and Exchange Commission (SEC) recently adopted new rules for private fund managers, which we covered in our alert SEC Adopts Expansive (Albeit Slightly Softened) Private Funds Rules. The new rules include...more
On January 12, 2022, Skadden partners Greg Norman and Anna Rips led the webinar “Challenges for Cross-Border Distribution of Private Funds in 2022,” which considered recent changes to the rules and regimes governing the...more
Side letters are an (increasingly) common way of formalising negotiated arrangements between a private fund and an investor. Whilst used more widely in the closed-ended fund context (given the limited withdrawal rights...more
In this issue: - SEC Division of Corporation Finance Issues New C&DI Related to Resales Under Regulation S - SEC Announces Proxy Voting Roundtable - CFTC Staff Issues No-Action Relief From Certain...more
In this issue: - SEC Sets October 2015 Target Date for Certain Dodd-Frank and JOBS Act Rulemaking - FINRA Issues Notice on TRACE Trade Reporting Obligations - NFA Issues Guidance on Exempt and Excluded...more
In this issue: - Delaware Court of Chancery Rejects Controlling Stockholder Claims and Applies Business Judgment Rule to Merger Suits - FINRA Remarks at the National Society of Compliance Professionals...more
In this issue: - Bylaw of Delaware Corporation Providing for Exclusive Forum in North Carolina Upheld - FINRA Board to Consider Rule Proposals Regarding Private Trading Platforms - CBOE and C2 in...more
Amendments to Offshore Fund Rules to Reflect Finance Act 2014 AIFM Partnership Tax Changes - Regulations amending the Offshore Funds Regulations 2009 (the 2009 Regulations) to reflect the Finance Act 2014 changes to...more
Registered investment companies that pursue alternative investment strategies (also referred to as "liquid alts") are a relatively new form of offering for investment managers accustomed to operating private investment funds....more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a National Examination Program Risk Alert that summarizes OCIE staff observations on investment adviser due diligence practices with respect to...more
Adopted by the European Parliament in 2010 and implemented by EU member states in July 2013, the Alternative Investment Fund Managers Directive (the Directive) seeks to protect investors and mitigate market instability by...more
CFTC Proposed Rule on Commodity Pools - On November 5, the CFTC issued a proposed rule that would require that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors...more
In This Issue: CFPB Final Rule Amendments to Ability to Repay and QM Rule; Extension of Loan Modification Programs; Freddie Mac $1 Billion Performing Modified Loan Securitization; FinCEN Guidance on Virtual Currency...more
The Alternative Investment Fund Managers Directive (the “Directive”) will introduce new regulatory reporting requirements for alternative investment fund managers (“AIFMs”) covered by the Directive. These will include all...more