News & Analysis as of

Liquidity Securities and Exchange Commission (SEC) Enforcement Actions

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Grants Broker-Dealers Permanent Exemptive Relief From Rule 15c2-11 for Fixed-Income Securities Sold Under Rule 144A Safe...

On October 30, 2023, the Securities and Exchange Commission (SEC) issued an order granting broker-dealers exemptive relief from Rule 15c2-11 of the Securities Exchange Act of 1934 for fixed-income securities sold in...more

Kilpatrick

SEC’s First Liquidity Rule Enforcement Action Signals New Focus

Kilpatrick on

On May 5, 2023, the Securities and Exchange Commission (the “SEC”) announced its first enforcement action against an investment adviser for violations of Rule 22e-4(b) (the “Liquidity Rule”) of the Investment Company Act of...more

Proskauer Rose LLP

SEC Brings First Liquidity Rule Enforcement Action Against Investment Adviser and Fund Board

Proskauer Rose LLP on

On May 5, 2023, the Securities and Exchange Commission ("SEC") filed charges against Pinnacle Advisors LLC ("Pinnacle Advisers"), an investment adviser, for allegedly aiding and abetting violations of Rule 22e-4 (the...more

Goodwin

SEC Files First Enforcement Complaint Under Liquidity Rule

Goodwin on

On May 5, 2023, the U.S. Securities & Exchange Commission filed its first enforcement complaint under Rule 22e-4 of the Investment Company Act of 1940, 17 C.F.R. § 270.22e-4 (the Liquidity Rule). The complaint was brought...more

Snell & Wilmer

Annual Reporting Considerations

Snell & Wilmer on

COVID-19 Considerations. Following the onset of the COVID-19 pandemic, the SEC has twice issued guidance for public companies addressing disclosure considerations in light of COVID-19.1 This guidance remains useful as...more

Goodwin

SEC Adopts Rule Providing New Regulatory Framework For Fund-Of-Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more

Kilpatrick

Investment Management Regulation: Year in Review

Kilpatrick on

As we prepare for a new year of regulatory initiates and actions, we believe it is important to take inventory of the most significant regulatory events from the past year. True to its word, the SEC focused on reducing...more

A&O Shearman

Financial Regulatory Developments Focus - November 2018 #4

A&O Shearman on

In this week’s newsletter, we provide a snapshot of the principal U.S., European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Vedder Price

Investment Services Regulatory Update - April 2018

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - PROPOSED RULES - SEC Proposes Changes to Fund Liquidity Disclosure Requirements - On March 14, 2018, the SEC issued proposed amendments to the disclosure requirements...more

Vedder Price

Investment Services Regulatory Update - February 2018

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more

Vedder Price

Investment Services Regulatory Update - August 2017

Vedder Price on

On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more

Foley & Lardner LLP

A Compilation of Non-Enforcement and Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - Mutual Fund Directors Must Be Vigilant in Addressing Risks - In remarks to the Mutual Fund Directors Forum, SEC Chair Mary Jo White outlined some of the risks and challenges that mutual fund...more

Ballard Spahr LLP

Investment Management Update - April 2016

Ballard Spahr LLP on

Below 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

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

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