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
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 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