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Checked Swing—SEC Does Not Adopt "Swing Pricing" or a "Hard Close" for Now, but Only Provides Liquidity Guidance and Amendments to...

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

SEC Increases the "Qualified Client" Net Worth and Assets Under Management Thresholds

INTRODUCTION - On 17 June 2021, the U.S. Securities and Exchange Commission (the SEC) issued an order to: (i) increase the net worth threshold for “qualified clients” under Rule 205-3 of the Investment Advisers Act of 1940,...more

SEC Adopts New Rule 12d1-4 Overhauling Fund of Funds Arrangements--Are You Ready?

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

SEC Issues New Guidance for Investment Advisers on Proxy Voting

OPEN MEETING OUTCOME - At an Open Meeting on August 21, 2019, the Securities and Exchange Commission (the “Commission” or “SEC”) voted three to two in favor of publishing guidance (the “Guidance”) addressing the...more

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