News & Analysis as of

No-Action Letters

Orrick's Financial Industry Week In Review

Division of Investment Management of the SEC Issues No-Action Letter to SSB - On May 8, 2018, the Chief Counsel's Office of the Division of Investment Management ("IM") of the Securities and Exchange Commission (the...more

Division of Investment Management of the SEC Issues No-Action Letter to SSB

On May 8, 2018, the Chief Counsel’s Office of the Division of Investment Management (“IM“) of the Securities and Exchange Commission (the “Commission“) issued a “no-action” letter to South State Bank (“SSB“) with respect to...more

SEC Proposes Amendments to Auditor Independence Rule to Address the “Loan Provision”

by Dechert LLP on

The U.S. Securities and Exchange Commission (SEC) voted unanimously on May 2, 2018 to propose amendments to Rule 2-01(c)(1)(ii)(A) under Regulation S-X – the so-called “Loan Provision” (Proposal). Generally, the Loan...more

Fifth Circuit Throws Out DOL Fiduciary Rule

by Liskow & Lewis on

The United States Fifth Circuit Court of Appeal vacated the entire DOL Fiduciary rule in a split decision on March 15, 2018, U.S. Chamber of Commerce v. DOL, No. 17-10238 (5th Cir. 3/15/2018). Two other circuits have upheld...more

Financial Services Weekly News - March 2018 #3

by Goodwin on

Editor's Note - D.C. Circuit Strikes Down Key Pieces of FCC’s TCPA Interpretive Order. On March 16, the U.S. Court of Appeals for the D.C. Circuit issued its long-awaited decision in ACA International v. FCC, invalidating...more

Corporate and Financial Weekly Digest, Featuring Topics on Broker/Dealer, CFTC and UK/EU/Brexit Developments

BROKER-DEALER - FINRA Requests Comment on Proposed New Rule Governing Outside Business Activities On February 26, the Financial Industry Regulatory Authority released Regulatory Notice 18-08, which solicits comments on...more

SEC Staff Issues First No-Action Letter Under “Economic Relevance” Exclusion Following Updated Guidance

by Ropes & Gray LLP on

On February 22, 2018, the staff of the SEC’s Division of Corporation Finance (the Division) issued a favorable no-action response to Dunkin’ Brands Group, Inc. under Rule 14a-8(i)(5) (the economic relevance exception)...more

SEC Grants Section 3(c)(5)(C) Relief to Depositor of Mortgage Securitization Trusts

by Morgan Lewis on

The US Securities and Exchange Commission staff has confirmed that a depositor of mortgage securitization trusts may rely on the exclusion from registration provided by Section 3(c)(5)(C) of the Investment Company Act of...more

SEC Staff Grants a Closed-End Fund No-Action Relief Under Rule 486(b) Covering Securities Other Than Common Stock

by Dechert LLP on

The staff of the Division of Investment Management (Staff) of the U.S. Securities and Exchange Commission (SEC or Commission) on February 14, 2018 issued a no-action letter (Letter) that would specifically permit the...more

New SEC Staff Guidance Broadens the Applicability of 1940 Act Exemption for Mortgage Securitizers

by Shearman & Sterling LLP on

In a no-action letter dated February 12, 2018, the SEC expanded the scope of Section 3(c)(5)(C) of the Investment Company Act to apply to a sponsor of multiple securities trusts that hold whole mortgage loans....more

Financial Services Weekly News - January 2018 #3

by Goodwin on

Editor's Note - “Humility and Prudence” at the CFPB. In a memo to employees of the Consumer Financial Protection Bureau (CFPB) later turned into a Wall Street Journal op-ed, Acting CFPB Director Mick Mulvaney articulated his...more

Analysis of the SEC’s MiFID II No-Action Relief

by Proskauer Rose LLP on

On October 26, 2017, the Securities and Exchange Commission ("SEC" or the "Commission") staff issued three no-action letters to help broker-dealers, investment advisers and investment companies comply with the European...more

SEC’s Mixed Guidance on Apple Environmental and Human Rights Shareholder Proposals Provides Clarification on CSR Proposals

Recent, seemingly disparate action by the Securities and Exchange Commission (SEC) with respect to two shareholder proposals may leave companies and shareholders confused as to whether companies may exclude shareholder...more

Broker-Dealer Beat - December 2017

by Proskauer Rose LLP on

Unbundling research and execution costs for money managers subject to MiFID II means that US broker-dealers can expect to receive hard dollars or other separately identified payments for research, at least from EU managers....more

Presentation and Portability of Investment Adviser Performance

by Foley & Lardner LLP on

An investment adviser’s investment track record is an important resource when raising capital from prospective investors. However, investment advisers, particularly registered investment advisers or emerging fund managers,...more

Investment Services Regulatory Update - November 2017

by Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more

Starting Up the CFPB’s No-Action Letter Program

The expanding use of mobile technologies, cloud computing, and the Internet of Things has greatly increased the amount of available consumer data. The ability to efficiently process this information has the potential to...more

SEC Releases Timely Guidance on Shareholder Proposals

by White & Case LLP on

On November 1, 2017, the staff (the "Staff") of the Division of Corporation Finance of the Securities and Exchange Commission (the "SEC") released Staff Legal Bulletin No. 14I (the "Guidance"), providing guidance on the...more

SEC Staff Issues No-Action Relief to Facilitate Implementation of MiFID II Research Provisions

by Goodwin on

On October 26, 2017, the staff (the Staff) of the U.S. Securities and Exchange Commission (SEC) issued three related no-action letters providing market participants with greater clarity as to how certain aspects of their...more

SEC Issues New Guidance on Shareholder Proposals

by Foley & Lardner LLP on

On November 1, 2017, the Division of Corporation Finance of the U.S. Securities and Exchange Commission (SEC) released Staff Legal Bulletin No. 14I (SLB 14I), which provides important guidance to public companies reviewing...more

SEC Issues New Guidance on Shareholder Proposals

by Foley & Lardner LLP on

On November 1, 2017, the Division of Corporation Finance of the U.S. Securities and Exchange Commission (SEC) released Staff Legal Bulletin No. 14I (SLB 14I), which provides important guidance to public companies reviewing...more

SEC Issues No-Action Letters to Ease U.S. and MiFID II Compliance; EC Issues Guidance on MiFID II Advisers’ Receipt of Research...

by Ropes & Gray LLP on

On October 26, 2017, the SEC staff issued three no-action letters to, respectively, the Investment Company Institute (the “ICI Letter”), the Securities Industry and Financial Markets Association’s Asset Management Group (the...more

SEC Releases Pro-Issuer Guidance on Shareholder Proposals

by Stinson Leonard Street on

The U.S. Securities and Exchange Commission staff’s release of Staff Legal Bulletin No. 14I ahead of the upcoming proxy season appears to reflect several issuer-friendly modifications to the staff’s processing of no-action...more

SEC provides relief to US firms attempting to comply with EU MiFID II's research "unbundling" provisions

by DLA Piper on

The US Securities and Exchange Commission provided welcome relief for US broker-dealers engaging in securities business with European investment managers when it issued three no-action letters designed to balance the...more

SEC Tackles MiFID II Research Issues

by Morgan Lewis on

But do landmines remain? On October 26, 2017, the staff of the Securities and Exchange Commission (SEC), following consultation with European authorities, issued three coordinated no-action letters to, in the words of one...more

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