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August 30 Deadline for TIC Form SHL

Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

SEC Amends Regulation S-P to Require Data Breach Notifications and Additional Written Policies

On May 16, 2024, the SEC amended Regulation S-P to impose new data privacy and security requirements on broker-dealers, registered investment advisers, investment companies (whether or not they are registered with the SEC),...more

T+1 Settlement Cycle: Implications for Investment Advisers

Starting May 28, 2024, the settlement cycle for most transactions in U.S. securities will shorten from T+2 to T+1 as a result of rule amendments adopted by the Securities and Exchange Commission (SEC).1 The SEC also adopted a...more

SEC Adopts Rules Expanding the Definitions of “Dealer” and “Government Securities Dealer”

On February 6, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to the definitions of “dealer” and “government securities dealer” that would subject certain market participants acting as liquidity...more

SEC Enforcement of Off-Channel Communications Continues - New Series of Firms Charged with Penalties Totaling $289 Million

Summary of the Recent SEC Actions - On August 8, 2023, in yet another set of enforcement actions in the space, the U.S. Securities and Exchange Commission (the “SEC”) settled charges against ten broker-dealers and a dually...more

Expiration of SEC Staff’s No Action Letters Providing Relief to Broker-Dealers Regarding MiFID II Research Requirements

Expiration of SEC Staff’s No Action Letters Providing Relief to Broker-Dealers Regarding MiFID II Research Requirements - On July 3, 2023, the U.S. Securities and Exchange Commission (the “SEC”) let expire a long-standing...more

SEC Division of Examinations Announces 2023 Priorities

On February 7, 2023, the SEC’s Division of Examinations (the “Division”) announced its 2023 examination priorities (“Examination Priorities”). The Division indicated that 2023 examinations will prioritize several significant...more

SEC Charges Sixteen Firms for Recordkeeping Failures Related to Employee Use of Personal Devices

On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more

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