Who may be interested: Registered Investment Companies; Boards of Directors; and Investment Advisers. Quick Take: The staff of the SEC Division of Investment Management (Staff) recently issued a no-action letter stating...more
On September 22, 2023, the Commodity Futures Trading Commission’s (the “CFTC” or the “Commission") Division of Market Oversight extended its no-action position regarding certain large trader reporting (“LTR”) obligations for...more
On December 22, just before many of us may have started turning to our holiday breaks, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)...more
Interest in engaging in a crypto business seems to be at an all-time high, including doing so in or through regulated and compliant businesses in traditional financial services firms. Brokers-dealers sit atop that list....more
Key Points - Until August 12, 2025, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account...more
Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2022. The conflict minerals disclosure rules and related guidance have remained at...more
On November 3, 2021, Corp Fin issued new guidance which signals a major shift in the SEC’s approach to no-action requests to exclude shareholder proposals relating to environmental and social ("E&S") matters. Previously, the...more
As calendar year-end companies received shareholder proposals for their 2021 annual meetings, they faced a variety of uncertainties and challenges, including navigating the COVID-19 pandemic, addressing the racial inequities...more
REGULATORY UPDATES - SEC - Leadership Changes On April 14, 2021, the U.S. Senate voted to approve President Biden’s nomination of Gary Gensler as Chairman of the Securities and Exchange Commission (the “SEC”) through June...more
In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more
The no-action relief applies to family offices with at least US$50 million in total assets (Institutional Family Offices) and requires broker-dealers seeking to rely on the relief to establish and maintain specific additional...more
In this issue, we provide a summary retrospective of regulatory, litigation and industry developments impacting the investment management sector during the second half of 2020, including SEC guidance and exemptive orders...more
The no-action letter is the first to expressly permit token transfer off-platform to non-users and conversion to fiat currency by token holders. As crypto prices surge, we find ourselves in the midst of another crypto wave....more
The ability to raise capital is one of the most critical challenges facing small businesses in the U.S. today. Capital can allow for exponential growth of a well-run startup with a good idea, but the lack of capital is the...more
U.S. Developments - Federal and State Regulatory Developments - U.S. Department of Homeland Security Issues Challenge for Development of Trusted User Interface for Digital Wallets - The U.S. Department of Homeland Security...more
On May 27, 2020, the Securities and Exchange Commission’s (SEC) Division of Investment Management (Division) issued a no-action letter (the Letter) that confirmed that registered open-end and closed-end investment companies...more
On May 27, 2020, the staff of the Division of Investment Management (Staff) of the Securities and Exchange Commission (SEC) issued a statement regarding the intersection between state control share acquisition statutes...more
As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than June 1, 2020. This remains true despite the impact of COVID-19, given that...more
The COVID-19 pandemic has caused unprecedented economic disruptions worldwide. Businesses that were previously flourishing are now seeing rapid declines in demand and revenue, disruptions in their supply chains, and other...more
On March 26, 2020, the Securities and Exchange Commission (SEC) issued No-Action Relief that allows an affiliated person of an open-ended investment company other than a money market fund or an exchange-traded fund to...more
On March 26, 2020, the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) took a substantial step in recognition of the significant securities market disruptions related to COVID-19 and granted...more
On March 26, the Staff of the Securities and Exchange Commission (SEC) granted a request for no-action relief to permit certain affiliated purchase transactions involving registered open-end investment companies....more
The pandemic coronavirus (“COVID-19”) continues its unprecedented disruption of the economy and markets....more
The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue...more
Many Commodity Futures Trading Commission registrants and other market participants are responding to the coronavirus (COVID-19) pandemic by implementing business continuity plans that move personnel from their “normal...more