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Policies and Procedures Compliance Disclosure Requirements

Snell & Wilmer

SEC Reporting Update - December 2024

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Insider Trading Policies. As previously discussed in our Winter 2022-2023 Corporate Communicator, the Securities and Exchange Commission (“SEC”) adopted final rules in December 2022 relating to insider trading policy...more

Seward & Kissel LLP

SEC Staff Issues Risk Alert Regarding Examination Process for Registered Funds

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Who may be interested: Registered Investment Companies; Advisers to Registered Investment Companies; Compliance Officers; Board of Directors - Quick Take: The SEC staff (Staff) published a risk alert (Alert) summarizing...more

Katten Muchin Rosenman LLP

SEC Division of Examinations Highlights Common Deficiencies in Registered Investment Company Core Examination Areas

On November 4, the Securities and Exchange Commission's (SEC) Division of Examinations (Division) published an analysis of the most common deficiencies identified across its three core registered investment company (RIC)...more

Health Care Compliance Association (HCCA)

In This Month’s E-News: November 2024

On the heels of a $7.6 million payment by Cleveland Clinic to settle allegations of False Claims Act (FCA) violations and unallowable sharing of passwords, Michael Lauer, NIH deputy director for extramural research, penned a...more

Conyers

Responding to Regulatory Notices: A Litigator’s Perspective

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There are a variety of information gathering and other compulsory notices available to regulatory and enforcement agencies based in the Cayman Islands, as tools these agencies can draw on to carry out their functions. In this...more

Bass, Berry & Sims PLC

SEC Charges Former Public Company Director and CEO with Concealing Close Friendship with Company Executive

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As most public companies enter their fourth fiscal quarter and look ahead to filing their Form 10-Ks and proxy statements, a recent settlement agreement announced by the Securities and Exchange Commission (the SEC) serves as...more

Nilan Johnson Lewis PA

Massachusetts Enacts New Pay Transparency and Reporting Requirements

A newly enacted Massachusetts law—effective July 1, 2025—will require employers with 25 or more employees in the Commonwealth to disclose pay range information in job postings and, in certain circumstances, provide current...more

Latham & Watkins LLP

SEC Imposes New Cybersecurity Requirements on Broker-Dealers, Investment Companies, Registered Investment Advisers, and Transfer...

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Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. ...more

Neal, Gerber & Eisenberg LLP

EU Sets Key Artificial Intelligence Regulation Dates

On August 1, 2024, the regulation of artificial intelligence (AI) took a major leap forward as the EU AI Act officially entered into force. While the Act is enforced within the EU, its extraterritorial scope has important...more

NAVEX

The Value of a Platform Approach to Compliance

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Think of it as the compliance version of The Butterfly Effect – a small, unnoticed, action, or failure to act, somewhere in the organization that balloons over time into a much larger, material issue. Maybe an employee is...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding SEC’s Focus Amid Lack of Final AI Rules

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

Davis Wright Tremaine LLP

Investment Adviser Expectations in 2024

Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more

Seward & Kissel LLP

SEC Settles Charges Against Private-Equity Firm for Alleged Disclosure Policy Failures

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Quick Take: The SEC settled charges against a private-equity fund Adviser for failing to maintain and enforce policies and procedures reasonably designed to prevent the misuse of material nonpublic information (MNPI) and to...more

King & Spalding

OIG Increases Expectations for Compliance Officers in Its New Compliance Program Guidance – What Compliance Officers at...

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On November 6, 2023, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) issued its anticipated General Compliance Program Guidance (“GCPG”) for the health care industry. The GCPG serves as a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Holland & Hart LLP

OIG Issued Updated General Compliance Program Guidance for Healthcare Providers and Stakeholders

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On Monday, November 6, 2023, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) released its General Compliance Program Guidance (“GCPG”) for the general healthcare compliance community and...more

ArentFox Schiff

2024 Examination Priorities for Investment Advisers from SEC Division of Examinations

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The US Securities and Exchange Commission (SEC) Division of Examinations recently released its 2024 Examinations Priorities, a yearly report that provides insight into the Division’s areas of focus to improve compliance,...more

Akin Gump Strauss Hauer & Feld LLP

SEC Releases Risk Alert on EXAMS Process

Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more

Eversheds Sutherland (US) LLP

SEC seeks to finalize highly controversial private fund adviser ruleset - What we are looking out for

The US Securities and Exchange Commission (SEC) is holding an open meeting this Wednesday, August 23, to consider whether to adopt proposed rules under the Investment Advisers Act of 1940 that, if adopted as proposed, would...more

Latham & Watkins LLP

SEC Adopts Cybersecurity Disclosure Rules

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The SEC, by a 3-2 vote, has adopted new rules requiring companies to provide: ..current disclosure on Form 8-K within four business days of determining that a material cybersecurity incident has occurred; and ...more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Adopts Final Cybersecurity Rules for Public Companies

In a narrow 3-2 decision on July 26, the SEC adopted its final rule concerning cybersecurity risk management, strategy, governance, and incident disclosure (the “Final Rule”).  Below we highlight some of the principal changes...more

Keating Muething & Klekamp PLL

SEC Cybersecurity Disclosure Final Rule

On July 26, 2023, the Securities and Exchange Commission (“SEC”) adopted final rules, rule amendments and form amendments to expand and standardize disclosures regarding cybersecurity risk management, strategy, governance,...more

Proskauer Rose LLP

Fund Manager Securities and Compliance

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This Webinar aims to provide some practical advice regarding Generative AI (“Gen AI”) and the issues its presents for private fund managers related to securities law and compliance. To the presenters, this is an dynamic time...more

Foley Hoag LLP

Heightened Share Repurchase Disclosure Adopted by SEC

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The U.S. Securities and Exchange Commission (SEC) has adopted final rules that seek to modernize and improve disclosures related to stock buyback programs. The rules apply to all domestic issuers, Listed Closed-End Funds and...more

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