News & Analysis as of

Life Insurance No-Action Letters

Eversheds Sutherland (US) LLP

SEC grants no-action relief to delay payment from variable insurance contracts to protect vulnerable adults in cases of suspected...

Recently, in response to a request from the Committee of Annuity Insurers, the staff in the Chief Counsel's Office of the Securities and Exchange Commission's (SEC) Division of Investment Management issued a no-action letter...more

Carlton Fields

Expect Focus - Volume III, September 2023

Carlton Fields on

Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Carlton Fields

Use of Non-Binding SEC Staff Guidance Called Into Question

Carlton Fields on

Recent moves by the SEC could signal a shift away from the use of non-binding guidance in the form of no-action letters or other types of compliance and interpretive information that the SEC staff frequently publishes....more

Ballard Spahr LLP

Investment Management Update

Ballard Spahr LLP on

Here in is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry....more

Carlton Fields

Expect Slower SEC Processing of Investment Company Filings

Carlton Fields on

The SEC has reported to Congress that it expects the Division of Investment Management (IM) to provide comments at a slower pace during the 2018 and 2019 fiscal years....more

Carlton Fields

Broker-Dealers Can Hold Customers’ Initial Checks

Carlton Fields on

A recent SEC no-action letter gives broker-dealers more time to perform suitability and other reviews when opening certain customer accounts. The firms requesting the letter were affiliated with three different insurance...more

Eversheds Sutherland (US) LLP

CFTC Interprets “Swap” Definition In the Context of Longevity Risk Transfer

The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) recently addressed for the first time the CFTC’s definition of a “swap” as it applies to a specific insurance...more

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