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SEC’s Newly Established Crypto Task Force: An Ambitious Agenda to Fill in the Gaps

The Securities and Exchange Commission (SEC) has been moving quickly to change course on its approach to regulating digital assets. Even before President Trump issued executive order 14178, titled “Strengthening American...more

Expect Focus - Volume I, January 2025

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence - In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church &...more

Getting Clued In: How the SEC’s RILA Rulemaking Affects Variable Annuities

The recent rule and form amendments adopted by the SEC to facilitate the registration of registered index-linked annuities (RILAs) and market-value adjustment annuities (MVAs) on Form N-4 have been broadly welcomed by the...more

Expect Focus - Volume IlI, September 2024

Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

Adviser Loses Customer Crypto: Wallet Key Custody Not Airtight

On June 25, 2024, a final judgment was entered by a federal district court against investment adviser Lufkin Advisors LLC and its principal, Chauncey Lufkin, for losing access to a crypto wallet used to manage a client’s...more

Up, Up, and Away for RILA Regulation: SEC Adopts Long-Awaited Framework

On July 1, 2024, pursuant to congressional mandate, the SEC adopted a new registration framework for registered index-linked annuities (RILAs). In addition, the SEC has extended the ambit of this framework to include...more

A Sea Change in RILA Regulation: Navigating the New Waters

On July 1, 2024, the Securities and Exchange Commission adopted a new registration framework for registered index-linked annuity (RILA) contracts. RILA contracts allow investors to allocate purchase payments to one or more...more

New SEC RILA Rules: Implementation Issues and Practical Considerations

On July 1, 2024, the Securities and Exchange Commission (SEC) announced new rules for registered index-linked annuities (RILAs) and registered market-value adjustment annuities (MVAs). The new rules will significantly impact...more

Last Lap in SEC RILA Rulemaking: Critical Unresolved Issues

Congress directed the SEC to adopt a new registration statement for registered indexed annuities (RILAs) by the end of June. Several months ago, the SEC published its proposed registration statement and related rules. As we...more

Expect Focus - Volume I, January 2024

Funds Not Caged by SEC Names Rule Amendments: Roaming Room Remains - The SEC recently adopted amendments to its investment company “names” rule that apply to most SEC-registered funds, including underlying funds in which...more

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