News & Analysis as of

No-Action Letters Compliance

Orrick, Herrington & Sutcliffe LLP

FinCEN Pursues Its Next Steps, Posting its Priorities and Pondering a No-Action Process

The Financial Crimes Enforcement Network (FinCEN) has completed two of its early benchmark obligations arising out of the recently passed Anti-Money Laundering Act of 2020 (the “AML Act”)... First, pursuant to the AML Act,...more

WilmerHale

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

WilmerHale on

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Foley Hoag LLP

SEC Adopts New Marketing Rule for Investment Advisers

Foley Hoag LLP on

On December 22, 2020, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments under the Investment Advisers Act of 1940 modernizing the rules governing investment adviser marketing. The amendments replace and...more

Dorsey & Whitney LLP

First DOJ FCPA Opinion in Six Years

Dorsey & Whitney LLP on

The Department of Justice issued its first FCPA opinion in six years on August 14, 2020. Foreign Corrupt Practices Act Review, Opinion Procedure Release, No.: 20-01. The opinion process provides a mechanism by which a...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Illusory Promise or Real Change? Transition at CFTC Brings Hope for Dodd-Frank Act Revisions

Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more

Allen Matkins

White House Orders Agencies To Offer Opinion Letters Or Does It?

Allen Matkins on

Last month, the White House issued this fact sheet concerning two executive orders intended "to improve the transparency and fairness of government agencies and ensure that they are held accountable". The fact sheet describes...more

Bradley Arant Boult Cummings LLP

The CFPB (Yes, the CFPB!) Offers New Compliance Tools for Innovation

Companies that offer innovative consumer financial products and services have new tools to help them stay in compliance with federal consumer financial laws. In a refreshing twist from prior policy, the Consumer Financial...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - June 2019

In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more

Dechert LLP

Fund Boards May Rely on CCO Representations in Lieu of Quarterly Board Determinations Under Rules 10f-3, 17a-7 and 17e-1

Dechert LLP on

The Staff of the SEC’s Division of Investment Management has issued a no-action letter permitting a fund’s board to rely on written representations from the fund’s CCO in lieu of quarterly determinations that the fund’s...more

Morgan Lewis

SEC Staff Relieves Fund Boards of Certain Compliance Determinations

Morgan Lewis on

In a recent no-action letter, the US Securities and Exchange Commission staff relieved fund boards of directors of the responsibility for determining compliance with key affiliated transaction exemptive rules. Boards will now...more

Dechert LLP

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

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

Katten Muchin Rosenman LLP

Bridging the Week - February 2017 #2

Retail Foreign Exchange Dealer Agrees With CFTC and NFA to Cease Doing Business for Concealing Relationship With Closely Tied Market Maker - Forex Capital Markets, LLC, a retail foreign exchange dealer, and two of its...more

Fenwick & West LLP

Matchmaker, Matchmaker Make me a… 506(b) Private Placement Investment

Fenwick & West LLP on

The SEC has given the go-ahead to a venture capital firm’s plan to conduct 506(b) private placements online. On August 5, 2015, the Commission issued a no-action letter to Citizen VC, Inc., saying the firm’s proposed online...more

Dechert LLP

SEC Provides Guidance on Activities That Constitute "General Solicitation" for Private Placements on Electronic Platforms

Dechert LLP on

The U.S. Securities and Exchange Commission (the “SEC”) on August 6, 2015, issued a no-action letter to Citizen VC, Inc. (the “Citizen Letter”) and new compliance and disclosure interpretations (“C&DIs”), providing...more

Burr & Forman

FINRA Rule 2040 Goes Into Effect

Burr & Forman on

On August 24, 2015, FINRA Rule 2040 concerning payments to unregistered persons went into effect. The rule, approved by the SEC in January 2015, is aligned with § 15(a) of the Securities Exchange Act of 1934. Generally, FINRA...more

Adler Pollock & Sheehan P.C.

Glossary of Important Securities Regulation Terms and Definitions

This Glossary is designed to provide law students taking Securities Regulation with a tool that will assist them in learning the basic language of securities law and achieve a working knowledge of the fundamental principles...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Corporate Finance Alert: SEC Staff Issues Interpretations on General Solicitation Prohibition"

The staff of the SEC Division of Corporation Finance (Staff) recently issued new Compliance and Disclosure Interpretations (CDIs) and an interpretive letter regarding the general solicitation prohibition in securities...more

Davis Wright Tremaine LLP

CFPB Proposes No-Action Letter Policy for Innovative Products

The Consumer Financial Protection Bureau has proposed a no-action letter policy under which the agency would issue letters stating that its staff “has no present intention to recommend initiation of an enforcement or...more

Burr & Forman

Dodd-Frank News: October 2014: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

Burr & Forman on

In This Issue: - RECENT CASES .. Mortgage Servicing Rules .. Antiretaliation Provision ..Credit Default Swaps Antitrust Litigation ..CFPB Involvement in Litigation - IN THE...more

Ballard Spahr LLP

CFPB Proposes No-Action Letter Policy for Innovators

Ballard Spahr LLP on

The CFPB published for comment in today’s Federal Register a proposed policy on issuing “no-action” letters for innovative financial products or services. Like those issued by the SEC and CFTC, the no-action letters would...more

Latham & Watkins LLP

CFTC Staff Issues Relief from Ownership and Control Reporting Rules

Latham & Watkins LLP on

The conditional, time-limited no-action letter extends certain compliance deadlines under the new rules. On November 18, 2013, the US Commodity Futures Trading Commission (CFTC) published final rules on Ownership and...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 17

In this issue: - Proposed Amendments to Delaware General Corporation Law and Courts and Judicial Procedure Law - SEC Division of Corporation Finance Issues New C&DIs Relating to Social Media Use - FINRA...more

Foley & Lardner LLP

A Compilation of Actions - April 01, 2014

Foley & Lardner LLP on

In a recent SEC no-action letter (RS Global Natural Res. Fund, SEC no-action letter, available 3/6/14), the SEC stated that it would take a non-enforcement position if a SEC registered investment adviser to a fund registered...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Provides Updated Guidance on ‘Knowledgeable Employee’ Status Under the Investment Company Act of 1940"

On February 6, 2014, the Division of Investment Management of the Securities and Exchange Commission (the “SEC”) issued a no-action letter to the Managed Funds Association (the “MFA No-Action Letter”) providing updated...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Provides No-Action Relief to M&A Brokers in Connection With Broker-Dealer Registration Requirements"

On January 31, 2014, the Division of Trading and Markets (the “Division”) of the Securities and Exchange Commission (the “SEC”) issued a no-action letter (as revised on February 4, 2014, the “No-Action Letter”) that permits...more

32 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide