News & Analysis as of

Securities and Exchange Commission (SEC) Form 13F

WilmerHale

Reminder for all 13F Filers: Form N-PX is due this month - by August 31, 2024

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Mutual funds and other registered investment companies have long had an obligation to file Form N-PX, giving the SEC and the public access to how a fund voted proxies on an annual basis. New Rule 14Ad-1 under the Securities...more

Stark & Stark

Navigating the New Compliance Landscape: Understanding Rule 14Ad-1 and Form N-PX Filing

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New Rule 14Ad-1 takes effect on July 1, 2024, with filing of Form N-PX due on August 31, 2024, for votes during the July 1, 2023 to June 30, 2024 reporting period. ...more

Sullivan & Worcester

Deadline for Form 13F Filers for New Reporting Requirements on Executive Compensation Votes Rapidly Approaching

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The Securities and Exchange Commission adopted rule and form amendments that will require institutional investment managers who file Form 13F to use Form N-PX to report how they voted proxies on executive compensation (or...more

Goodwin

New Proxy Voting Reporting Requirements For Investment Managers For 2023-24 Annual Meeting Season

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On November 2, 2022, the U.S. Securities and Exchange Commission (SEC) announced the adoption of amendments to Form N-PX and related rules to extend public company stockholder vote disclosure filing requirements beyond...more

Cooley LLP

What Fund Managers Need to Know About SEC Form N-PX

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A Securities and Exchange Commission (SEC) rule that takes effect on July 1, 2024, will require fund managers who file Form 13F reports to publicly report – on an annual basis on Form N-PX – the manner in which they vote on...more

Cooley LLP

New SEC Requirements for Form 13F Filers Effective July 1, 2024

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In late 2022, the Securities and Exchange Commission (SEC) adopted rule changes that will require institutional investment managers who file Form 13F to annually file a Form N-PX disclosing the manner in which they have voted...more

Vedder Price

2024 Annual Compliance Obligation Reminders

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Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state as well as commodity pool operators (“CPOs”) and commodity trading advisers (“CTAs”) registered with the U.S. Commodity...more

Cooley LLP

Annual SEC Filing Deadline for Venture, Private Equity Funds Is February 14, 2024

Cooley LLP on

Venture and private equity funds that own equity securities of public companies may have numerous Securities and Exchange Commission (SEC) filing requirements, including filings based on the size of the holdings of a...more

Cooley LLP

Annual SEC Section 13 Filing Requirements for Venture, Private Equity Funds - December 2023

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Venture and private equity funds that own equity securities of public companies may have numerous Securities and Exchange Commission filing requirements, including filings based on the size of the holdings of a particular...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

New Form N-PX Reporting - A Practical Guide for Form 13F Filing Managers

Institutional investment managers that file Form 13F (each, an “Institutional Manager”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), will be required to file their first Form N-PX as soon as...more

Morgan Lewis

New SEC Rule Requires 13F Filers to Track and Report on Proxy Voting

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Institutional investment managers that file on Form 13F must make public filings on Form N-PX to report their “say-on-pay” proxy voting. Although the compliance date for this new filing requirement is not until August 2024,...more

Latham & Watkins LLP

Form N-PX “Say on Pay” Disclosure Requirement for 13F Filers Will Become Effective July 1, 2024

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Form 13F filers will need to file their first Form N-PX covering the period of July 1, 2023, to June 30, 2024, by August 31, 2024. Rule 14Ad1 of the Securities Exchange Act of 1934 (Exchange Act), which was adopted by...more

Cooley LLP

Annual SEC Filing Deadline for Venture, Private Equity Funds Is February 14, 2023

Cooley LLP on

Venture and private equity funds that own equity securities of public companies may have numerous Securities and Exchange Commission filing requirements, including filings based on the size of the holdings of a particular...more

Latham & Watkins LLP

SEC Adopts Amendments to Form 13F

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Changes include switching from paper to electronic filing requirement for confidential treatment requests. On June 23, 2022, the Securities and Exchange Commission (SEC) adopted certain amendments to Form 13F (the Adopting...more

Proskauer Rose LLP

SEC Proposes Monthly Short Sale Reporting Requirements: Aggregated Information to be Public; New Order Marking Requirements...

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The SEC recently proposed to require investment managers to report short sale information on a monthly basis if such activity exceeds certain thresholds, and to require broker dealers to begin to mark “buy to cover” trades...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and...more

Cooley LLP

Annual SEC Filing Deadline for Venture and Private Equity Funds Is February 14, 2022

Cooley LLP on

Venture and private equity funds that own equity securities of public companies may have numerous Securities and Exchange Commission filing requirements, including filings based on the size of the holdings of a particular...more

Kilpatrick

SEC Proposes Enhanced Proxy Voting Disclosures for Investment Funds and Institutional Investment Managers

Kilpatrick on

With the stated goal of making it easier for investors to identify votes of interest and compare and analyze voting records, on September 29, 2021, the SEC released a proposed rule and amendments to Form N-PX (collectively,...more

Faegre Drinker Biddle & Reath LLP

SEC Proposes Rules for Enhanced Reporting of Proxy Voting by Registered Investment Companies and Reporting on Executive...

On September 29, 2021, the U.S. Securities and Exchange Commission (SEC) proposed amendments to Form N-PX to provide greater transparency to the information registered management investment companies (Funds) report about...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions - October 2020

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REGULATORY UPDATES - SEC Adopts Amendments to Exemptive Applications Procedures - On July 6, 2020, the Securities and Exchange Commission (the “SEC”) announced the adoption of rule amendments that establish an expedited...more

Robins Kaplan LLP

Financial Daily Dose 9.9.2020 | Top Story: Luxury-Goods Giant LMVH Pulls Out of $16 Billion Deal to Acquire Tiffany & Co.

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Blaming a “U.S. move to impose tariffs on French goods,” luxury brand conglomerate LMVH is pulling out of a proposed $16 billion deal to buy jeweler Tiffany & Co. Tiffany is now suing to enforce the ill-fated agreement....more

Fenwick & West LLP

Proposed Form 13F Changes Would Reduce Visibility into Stockholder Base and Activist Activities

Fenwick & West LLP on

The U.S. Securities and Exchange Commission (SEC) has announced a proposed amendment to the filing requirements for Form 13F, which is expected to decrease the number of institutional investment managers required to report...more

Robins Kaplan LLP

Financial Daily Dose 8.18.2020 | Top Story: U.S. Further Restricts Huawei Access to American Components

Robins Kaplan LLP on

Another day, another major U.S. restriction on Chinese tech. The Commerce Department is out with new rules “curbing Huawei Technologies Co.’s access to foreign-made chips.” The measures would “prohibit non-U.S. companies from...more

K&L Gates LLP

SEC Proposes Amendments to Form 13F, Proposes Increasing 13F Reporting Threshold

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On 10 July 2020, the Securities and Exchange Commission (SEC) proposed amending Form 13F and Rule 13f-1 to raise the reporting threshold at which institutional investment managers are required to complete and file Form 13F...more

Kilpatrick

Adjusting for Inflation The SEC Proposes Raising the Form 13F Reporting Threshold from 100

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On July 10th, the SEC proposed amendments to Exchange Act Rule 13f-1 that would raise the Form 13F reporting threshold from $100 million to $3.5 billion. If effected, this would be the first change to the reporting threshold...more

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