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Ethics › Investment Company Act of 1940

Dorsey & Whitney LLP

SEC Publishes Risk Alert with Observations from Examinations of Mutual Funds, Money Market Funds, and Target Date Funds

Dorsey & Whitney LLP on

On November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert highlighting the most often cited deficiencies and weaknesses observed in recent examinations of registered...more

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2015: Developing and Maintaining a Modern U.S. Compliance Program

Dechert LLP on

When the SEC adopted Rules 38a-1 under the Investment Company Act of 1940 (Investment Company Act) and 206(4)-7 under the Investment Advisers Act of 1940 (Advisers Act) in 2003 – which required registered funds and registered...more

Latham & Watkins LLP

Beyond Schrödinger's Cat: Why an Operating Company Can't be an "Investment Company" at the Same Time

Latham & Watkins LLP on

Erwin Schrödinger famously illustrated an aspect of quantum mechanics with a cat that is simultaneously both alive and dead. Schrödinger’s cat sometimes comes to mind when we are asked about inadvertent investment companies –...more

Broker-Dealer Compliance + Regulation

Giving the CCO Teeth: SEC Sanctions Portfolio Manager for Misleading CCO

Broker-Dealer Compliance + Regulation on

The SEC brought its first action for misleading and obstructing the work of a CCO this week, finding that a portfolio manager deliberately altered documents and misled the firm’s CCO in an attempt to hide violations of the...more

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