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Investment Company Act of 1940 Money Market Funds

K&L Gates LLP

US Asset Management Regulatory Year in Review 2023

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It is a dramatic understatement to describe 2023 as a busy year in the United States for asset management regulation. With 24 rules adopted and 18 new rules or rule amendments proposed, the US Securities and Exchange...more

K&L Gates LLP

A Deep Dive into Money Market Fund Liquidity Fees

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Executive Summary - On 12 July 2023, the Securities and Exchange Commission (the SEC) adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Final Rule), which governs the...more

Seward & Kissel LLP

SEC Adopts Money Market Fund Reforms

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Who may be interested: Registered Investment Companies; Investment Advisers - Quick Take: The SEC adopted amendments to Rule 2a-7 governing money market funds under the Investment Company Act to improve the transparency...more

Goodwin

SEC Adopts Reforms for Money Market Funds

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On July 12, 2023, the US Securities and Exchange Commission ("SEC") voted, by a 3-2 vote, to adopt money market fund reforms that will significantly impact the regulatory framework governing money market funds ("money funds"...more

K&L Gates LLP

Out With the Old, in With the New – SEC Scraps Swing Pricing Proposal, Removes Redemption Gates, and Mandates Liquidity Fees for...

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In a surprising change, the SEC heeded the cacophony of opposition to swing pricing, but instead threw the industry a curveball by requiring mandatory liquidity fees for institutional prime and institutional tax-exempt money...more

Patterson Belknap Webb & Tyler LLP

SEC Moves to Strengthen Money Market Funds

On July 12, 2023, in a closely-watched meeting, the Securities and Exchange Commission approved new requirements on the $5.8 trillion money market fund (MMF) industry, a popular class of mutual funds that balance high...more

Kramer Levin Naftalis & Frankel LLP

SEC Adopts Amendments to Money Market Fund Rules

On July 12, the Securities and Exchange Commission (Commission) adopted amendments to Rule 2a-7 governing money market funds under the Investment Company Act of 1940 (1940 Act). ...more

K&L Gates LLP

Proposed Money Market Fund Reforms Related to Negative Interest Rates Favor Conversion to Floating NAV and Prohibit Other...

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On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which governs the structure and...more

Dechert LLP

SEC Proposes New Round of Money Market Fund Reforms in Response to March 2020 Redemptions

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The Securities and Exchange Commission, by a vote of three-to-two, on December 15, 2021, proposed amendments (Proposed Amendments) to Rule 2a-7 and other rules that govern money market funds (money funds) under the Investment...more

K&L Gates LLP

SEC Proposes Swing Pricing for Institutional Money Market Funds

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SECTIONS - I. Introduction - II. Key Requirements for Swing Factor Implementation - III. When a Swing Factor Must Be Applied - IV. Calculation of the Swing Factor - V. The President’s Working Group 2020 White Paper and Prior...more

Faegre Drinker Biddle & Reath LLP

Money Market Funds: The SEC Seeks Comments for Proposed Rule Amendments

On December 15, 2021, the Securities and Exchange Commission (SEC) voted (three-two) to propose amendments to rules regulating money market funds under the Investment Company Act of 1940, which are designed to increase the...more

Dechert LLP

SEC Proposes Amendments to Rules Governing Money Market Funds (UPDATED)

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On December 15, 2021, the Securities and Exchange Commission, by a party-line vote of three-to-two, proposed for public comment amendments (Proposed Amendments) to Rule 2a-7 and other rules that govern money market funds...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

On December 15, 2021, the U.S. Securities and Exchange Commission (the “SEC”) voted, by a 3-2 vote, to propose money market fund reforms that would significantly impact the regulatory framework governing money market funds...more

K&L Gates LLP

SEC Proposes Another Round of Money Market Fund Reforms

K&L Gates LLP on

I. EXECUTIVE SUMMARY - On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

On December 15, the SEC voted to propose reforms that would significantly affect the regulatory framework governing money market funds (MMFs). According to the SEC, the proposed reforms are designed to improve the resiliency...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Major Amendments to Money Market Fund Rules

On Dec. 15, 2021, the Securities and Exchange Commission (SEC) voted to propose amendments to certain rules governing money market funds under the Investment Company Act of 1940 (the 1940 Act). The SEC indicated that the...more

White & Case LLP

Over 60 of the Nation's Leading Law Firms Respond to Investment Company Act Lawsuits Targeting the SPAC Industry

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Recently a purported shareholder of certain special purpose acquisition companies (SPACs) initiated derivative lawsuits asserting that the SPACs are investment companies under the Investment Company Act of 1940, because...more

Mayer Brown Free Writings + Perspectives

Multi-Firm Statement in Response to 1940 Act Suits Against SPACs

Today, 49 law firms, including Mayer Brown, signed a joint statement responding to a recent action against a SPAC asserting that SPACs are investment companies under the Investment Company Act of 1940 because proceeds from...more

Fox Rothschild LLP

Fund Adviser Exemptions Primer– Redux

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I never find it boring to review the investment adviser exemptions for private fund managers. Apparently, I am not the only one since this is a question we frequently field. Initially, private fund manager investment...more

Sullivan & Worcester

SEC Adopts New Valuation Rule under the 1940 Act

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On December 3, 2020, the Securities and Exchange Commission (SEC) adopted new rule 2a-5 ("Rule 2a-5") under the Investment Company Act of 1940, as amended ("1940 Act") addressing valuation practices and the board of...more

Dorsey & Whitney LLP

SEC Re-Proposes Exemptive Rule Relating to the Use of Derivatives by Registered Funds

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On Nov. 25, 2019 the Securities and Exchange Commission (SEC) voted to propose a new rule, under the Investment Company Act of 1940 (the “1940 Act”), designed to modernize the way the SEC regulates the use of derivatives by...more

Dechert LLP

SEC Proposes New Rules and Amendments to Update the Approach to the Regulation of Funds’ Use of Derivatives and Other Transactions

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The U.S. Securities and Exchange Commission on November 25, 2019 approved for publication a three-part rule proposal related to the use of derivatives and certain other transactions by registered investment companies (i.e.,...more

Dorsey & Whitney LLP

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

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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

CFTC Guidance on FCM and DCO Investments in Money Market Funds

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Divisions of the U.S. Commodity Futures Trading Commission (CFTC) on August 8, 2016 issued letters restricting futures commission merchants (FCMs) and derivatives clearing organizations (DCOs) from investing in money market...more

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