News & Analysis as of

Securities and Exchange Commission (SEC) Transaction Fees

Faegre Drinker Biddle & Reath LLP

The SEC Sues Investment Advisory Firm in Connection with Alleged Failure to Disclose Revenue Sharing and Other Financial...

In recent years, the SEC has been conducting a nationwide and industry-wide “sweep” of investment advisory firms, pursuant to which it has opened investigations and brought enforcement actions against a multitude of...more

Dechert LLP

SEC Proposes to Modernize Disclosure Framework for Mutual Funds and Exchange-Traded Funds, Modify Fee Information in Investment...

Dechert LLP on

The Securities and Exchange Commission on August 5, 2020 unanimously approved proposed rule and form amendments (Proposed Rule) that would comprehensively revise and update the disclosure framework for mutual funds and...more

K&L Gates LLP

SEC Proposes Major Changes to Prospectus and Shareholder Report Disclosure Scheme

K&L Gates LLP on

I. INTRODUCTION AND SUMMARY - The Securities and Exchange Commission (SEC) has proposed a bold new approach to shareholder and investor communications by investment companies registered on Form N-1A under the Investment...more

Goodwin

Financial Services Weekly Roundup: Treasury And SBA Codify Changes To PPP Flexibility Act

Goodwin on

In This Issue. The U.S. Department of the Treasury (Treasury) and the Small Business Administration (SBA) released an interim final rule to reflect changes made by H.R. 7010, the Paycheck Protection Program Flexibility Act,...more

Kilpatrick

ICI Joins in Fight Between the SEC and National Exchanges

Kilpatrick on

Last December, the SEC unanimously approved a two-year pilot program (the “Transaction Fee Pilot”) intended to assess alternatives to the predominant pricing model used by national securities exchanges (the “Maker-Taker...more

Sheppard Mullin Richter & Hampton LLP

Where is the Love? Exchanges Sue SEC Over Market Access Fee Pilot Program

Three prominent trading exchanges did not exactly show their government overseer the love this Valentine’s week. On February 14, 2019, the New York Stock Exchange (“NYSE”) filed a petition for review to the U.S. Court of...more

A&O Shearman

SEC Proposes Changes to Regulatory Framework of Fund of Funds Arrangements

A&O Shearman on

The Securities and Exchange Commission (the SEC) has proposed rules that would modernize the “fund of funds” rules. The rules would replace a patchwork of exemptive rules and orders, with the goal of a “consistent and...more

Eversheds Sutherland (US) LLP

The SEC’s litigation against a firm for allegedly inadequate disclosure of shareholder service fees and 12b-1 fees

During the past several years, the US Securities and Exchange Commission (SEC) has settled more than a dozen cases where the SEC alleged (with the firms neither admitting nor denying the charges) that investment advisers...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC’s Proposed Transaction Fee Pilot Program Continues to Provoke Discussion

On March 14, 2018, the Securities and Exchange Commission (SEC) proposed new Rule 610T of Regulation NMS, which would establish a pilot program to study the effects of potential changes considered by the SEC on certain...more

Dechert LLP

SEC Proposes Transaction Fee Pilot for NMS Stocks

Dechert LLP on

The U.S. Securities and Exchange Commission (SEC) voted unanimously on March 14, 2018 to propose Rule 610T under Regulation NMS (Proposed Rule), which would create a transaction fee pilot program for NMS stocks (i.e.,...more

WilmerHale

SEC Proposes Transaction Fee Pilot for NMS Stocks

WilmerHale on

On March 14, 2018, the Securities and Exchange Commission (SEC) proposed Rule 610T of Regulation NMS under the Securities Exchange Act of 1934 to conduct a pilot program (Pilot) to study the effect of equity exchange...more

McCarter & English, LLP

Additional Regulatory Hurdles for Private Equity Advisers

The private equity industry should carefully consider the implications of a recent Securities and Exchange Commission ("SEC") enforcement action. In it, the SEC, for the first time, sanctioned an SEC-registered private equity...more

Stinson LLP

Broker-Dealer Violations by Private Equity Fund Adviser

Stinson LLP on

For private equity funds, along with their managers, sponsors, investors, and portfolio companies paying or receiving transaction-based fees, the recent announcement by the Securities and Exchange Commission (SEC) of a...more

Neal, Gerber & Eisenberg LLP

SEC Sends Warning to General Partners of Funds Receiving Finders’ and Other Fees

On June 1, 2016, the SEC sent a warning to general partners of private investment funds (including private equity funds, hedge funds, venture capital funds and leveraged buyout funds) by entering into a settlement agreement...more

Bilzin Sumberg

How New SEC Focus Will Affect SFL Real Estate Private Equity

Bilzin Sumberg on

South Florida real estate private equity funds: take note of a recent speech by Marc Wyatt, SEC Director of Compliance, following up on previous concerns expressed regarding fees and expenses for private equity funds. ...more

Carlton Fields

Feds Dig for Disguised Fund Distribution Fees

Carlton Fields on

A nearly two-year SEC sweep examination of mutual funds’ payments for distribution and other services appears to have concluded. Now, the question is what, if any, enforcement or other action the SEC will take....more

Orrick - Finance 20/20

Fee Rate Advisory #3 for Fiscal Year 2015

Orrick - Finance 20/20 on

On January 15, the SEC announced that starting on Feb. 14, 2015, the fee rates applicable to most securities transactions will be set at $18.40 per million dollars. Each SRO will continue to pay the Commission a rate of...more

Troutman Pepper

Investment Management Update – Fees and Expenses

Troutman Pepper on

Pepper Hamilton’s Julia D. Corelli and PEF Services’ Anne Anquillare and Mark Heil, joined Pepper’s Gregory J. Nowak for his monthly webinar which he hosts for West LegalEdcenter. This month the webinar discussed a recent...more

Troutman Pepper

What’s Really Going on with PE Firms’ Fees?

Troutman Pepper on

Pepper Hamilton LLP, a multi-practice law firm that represents private equity clients throughout the life cycle of an investment fund, recently partnered with PEF Services and PEI to conduct a survey of 104 U.S. alternative...more

Burr & Forman

Reverse Churning

Burr & Forman on

It is obvious that broker-dealers and their registered representatives, as well as investment advisors, must be careful in making recommendations to their clients. But the rise of claims related to inaction in a client...more

Morrison & Foerster LLP

Investment Management Legal + Regulatory Update -- June 2014

In This Issue: - Regulation ..SEC Begins to Scrutinize Registrants’ Cybersecurity Practices ..SEC Staff Sets Boundaries for Adviser Testimonials in Social Media ..Chair White: SEC to Tackle High-Frequency...more

Broker-Dealer Compliance + Regulation

Securities Regulators Are Inspired by an Academic Article to Seek Information Regarding Order Routing

Apparently attempting to understand how broker-dealers provide best execution in the face of incentives to trade at certain exchanges, the SEC and FINRA are asking broker-dealers for extensive transaction information...more

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