EXECUTIVE SUMMARY On 28 August, 2024, the Securities and Exchange Commission (SEC) adopted amendments to reporting forms for registered investment companies (funds) that will (1) require funds to file monthly (rather than...more
9/13/2024
/ Asset Management ,
ETFs ,
Form N-CEN ,
Form N-PORT ,
Investment Advisers Act of 1940 ,
Investment Management ,
Liquidity ,
Registered Investment Companies (RICs) ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
I. SUMMARY - On 25 May 2022, the U.S. Securities and Exchange Commission (the SEC) proposed amendments (the Proposed Amendments) to Rule 35d-1 (the Names Rule) under the Investment Company Act of 1940, as amended in its...more
On 28 October 2020, the U.S. Securities and Exchange Commission adopted Rule 18f-4 under the Investment Company Act of 1940, as amended. The rule replaces the SEC’s decades-old patchwork of guidance with a comprehensive...more
I. EXECUTIVE SUMMARY - On 7 October 2020, the Securities and Exchange Commission (the SEC) adopted new rule 12d1-4 (Rule 12d1-4) and related amendments under the Investment Company Act of 1940 (the 1940 Act) that it believes...more
OVERVIEW OF THE ETF RULE -
- On September 25, 2019, the SEC approved Rule 6c-11 under the 1940 Act (the “ETF Rule”) and related amendments to Form N-1A
- The ETF Rule will rescind previously-issued exemptive orders of...more
DISCUSSION OVERVIEW -
- Duty to Establish a Compliance Program
- Chief Compliance Officer (“CCO”)
- Written Policies and Procedures
- Annual Review Process
- SEC Exams and Enforcement
- Code of Ethics
...more
OVERVIEW -
- Background
- Overview of the Rule
- Exemptions Granted by Rule
- Changes Made by Rule to Current ETF Regulatory Scheme
- Key Board Interests
...more
On October 12, 2018, the staff of the Division of Investment Management (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued a no-action letter to the Independent Directors Council (“IDC”) (“IDC Letter”)...more
On June 28, 2018, the Securities and Exchange Commission (“SEC”) amended certain disclosure requirements related to the “Liquidity Rule” — Rule 22e-4 — for open-end funds (except money market funds) registered under the...more
7/26/2018
/ Disclosure Requirements ,
Form N-PORT ,
Investment ,
Investment Companies ,
Investment Company Act of 1940 ,
Liquidity ,
Liquidity Risk Management Rule ,
Reporting Requirements ,
Risk Management ,
Rule 22e-4 ,
Securities and Exchange Commission (SEC)
On February 22, 2018, the Securities and Exchange Commission (“SEC”) adopted an interim rule (“Interim Rule”) that revised compliance dates for certain provisions of Rule 22e-4 under the Investment Company Act (the “Liquidity...more
On March 14, 2018, the Securities and Exchange Commission (“SEC”) proposed amendments to public liquidity-related disclosure requirements mandated by Rule 22e-4 under the Investment Company Act (the “Liquidity Rule”). ...more
On February 21, 2018, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management (the “Division”) issued additional guidance related to Rule 22e-4 under the Investment Company Act (“Liquidity Rule” or...more
On October 13, 2016, the Securities and Exchange Commission (“SEC”) adopted new Rule 22e-4 (“Liquidity Rule”) under the Investment Company Act of 1940 (“1940 Act”), which requires registered open-end funds, including open-end...more
On June 28, 2016, the Securities and Exchange Commission (the “SEC”) released a proposed rule (the “Proposed Rule”) that would require registered investment advisers (“RIAs”) to adopt written business continuity and...more
On December 11, 2015, the Securities and Exchange Commission (“SEC”) proposed new Rule 18f-4 under the Investment Company Act of 1940, as amended (“1940 Act”) to reduce leverage risks associated with derivatives and to...more
On September 22, 2015, the Securities and Exchange Commission (“SEC”) proposed a new rule and amendments to rules and reporting forms under the Investment Company Act of 1940 (the “1940 Act”), designed to standardize...more
10/26/2015
/ Comment Period ,
Compliance ,
Disclosure Requirements ,
EFTs ,
Exchange-Traded Products ,
Federal Register ,
Financial Institutions ,
Form N-CEN ,
Form N-PORT ,
FSOC ,
Hedge Funds ,
Investment ,
Investment Companies ,
Investment Company Act of 1940 ,
Investment Management ,
Investment Portfolios ,
Investors ,
Liquidity ,
Liquidity Risk Management Rule ,
Money Market Funds ,
Mutual Funds ,
New Guidance ,
Portfolio Managers ,
Public Comment ,
Regulation S-X ,
Reporting Requirements ,
Risk Assessment ,
Risk Management ,
Rule 22e-4 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Shareholders ,
Swing Pricing ,
U.S. Navy ,
UCITS
On May 20, 2015, the Securities and Exchange Commission (“SEC”) proposed rules, forms and amendments under the Investment Company Act of 1940 (the “1940 Act”) and related regulations (together, the “Proposed Amendments”) that...more
On June 30, 2014, the staff of the Securities and Exchange Commission’s (the “SEC”) Divisions of Investment Management and Corporation Finance issued Staff Legal Bulletin No. 20, which provides guidance on investment...more