News & Analysis as of

Sanctions Investment Company Act of 1940

Proskauer - The Capital Commitment

The Trend Continues: Increased Regulatory Focus on Privacy & Cybersecurity for Private Funds

Recent enforcement actions highlight the increased regulatory scrutiny that private funds may face with respect to internal cybersecurity protocols and responses to cyber-crimes and cyber incidents under new and updated...more

Kramer Levin Naftalis & Frankel LLP

SEC Staff Issues No-action Letter Regarding In-person Voting Requirements for Registered Investment Company

Following a request from the Independent Directors Council (a registered investment company board advocacy group affiliated with the trade association Investment Company Institute), the SEC staff has provided relief from...more

Carlton Fields

More Fund Companies Sanctioned for Misusing Fund Assets for Distribution

Carlton Fields on

The SEC recently settled enforcement actions against William Blair and two Calvert companies for using mutual fund assets to pay distribution-related expenses in violation of Investment Company Act Rule 12b-1 and for certain...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Goodwin

Financial Services Weekly News - September 2015 #4

Goodwin on

Regulatory Developments - NYDFS Announces Approval of First BitLicense Application from a Virtual Currency Firm: The New York State Department of Financial Services (NYDFS) announced Sept. 22 that it has approved...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Disclosure and Collateral Consequences of Enforcement Actions for Regulated Financial Services Firms"

Financial services firms facing enforcement proceedings at the hands of the U.S. Securities and Exchange Commission (SEC) or any other financial industry regulator must consider disclosure obligations in the context of the...more

Broker-Dealer Compliance + Regulation

Giving the CCO Teeth: SEC Sanctions Portfolio Manager for Misleading CCO

The SEC brought its first action for misleading and obstructing the work of a CCO this week, finding that a portfolio manager deliberately altered documents and misled the firm’s CCO in an attempt to hide violations of the...more

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