SEC Activity with Fixed Income and Credit Funds
On October 30, 2023, the US Securities Exchange Commission (the "SEC") issued an order (the "Order")1 granting broker-dealers exemptive relief from Rule 15c2-11 ("Rule 15c2-11") under the US Securities Exchange Act of 1934...more
Quick Take: The SEC charged an investment adviser in connection with improper trading in certain fixed income securities. The SEC’s order alleges that the adviser improperly traded the securities between advised clients,...more
Our Investment Management Alert from earlier this month described to private fund advisers the importance of the Security Exchange Commission’s (SEC’s) Division of Examinations recent Risk Alert on cross trades and principal...more
On July 21, 2021, the Division of Examinations (“Exams”) issued a risk alert on principal and cross trading practices by investment advisers (the “Risk Alert”). This Risk Alert supplements a prior risk alert published by...more
In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more
The Financial Industry Regulatory Authority published its 2019 Report on Examination Findings and Observations (2019 Report) on October 16, 2019. This marks the third annual report of FINRA findings, but in a departure from...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
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
On January 13, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released its 2015 examination priorities for investment companies, investment advisers, broker-dealers and...more
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
The Staff of the SEC’s Division of Investment Management issued IM Guidance Update 2014-1 which suggests risk management measures and related communications with fund boards that fund advisers may want to consider in view of...more