On August 27, the Securities and Exchange Commission (SEC) brought actions against four affiliated entities—including two registered investment advisers, one dually registered investment adviser and broker-dealer and a...more
On February 7, the US Securities and Exchange Commission's (SEC) Office of Compliance Inspections and Examinations (OCIE) published its examination priorities for 2018 (the "2018 Priorities Report"). Given that OCIE's...more
With the vast majority of European Union (EU) regulatory focus recently having been on the Markets in Financial Instruments Directive (MiFID II), it is important not to overlook the impending implementation of the EU's...more
On November 29, the US Department of Labor (DOL) finalized its 18-month extension of the transition period under the Best Interest Contract Exemption (the "BIC Exemption"). As described in Katten's earlier advisory,...more
On October 26, the Securities and Exchange Commission (SEC) issued three long-awaited letters clarifying how regulatory requirements in the European Union (EU), which go into effect on January 3, 2018, will impact US money...more
On August 9, the US Department of Labor (DOL) announced in a court filing that it has proposed an 18-month extension of the full implementation of the Best Interest Contract Exemption (the "BIC Exemption") under the ERISA...more
The DOL's "fiduciary advice rule" (the "Rule") will take effect on June 9, 2017. The DOL has published FAQs on the implementation of the Rule applicable to the period between June 9th and December 31st (the "Transition...more
Recently, the staff (Staff) of the US Securities and Exchange Commission's (SEC) Division of Investment Management issued an information update (the "Information Update") for investment advisers registered under the...more
Registered investment advisers should take note of recent pronouncements by the staff of the SEC's Division of Investment Management (the "Division") regarding Rule 206(4)-2 (the "Custody Rule") of the Investment Advisers Act...more
On August 25, the Securities and Exchange Commission (SEC) adopted amendments to Form ADV and to certain rules promulgated under the Investment Adviser Act of 1940, as amended (the "Advisers Act"). These amendments will be...more
In a speech on April 30, 2015. Securities and Exchange Commission (SEC) Chair Mary Jo White noted that...
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On June 28, the Securities and Exchange Commission (SEC) proposed a new rule, Rule 206(4)-4 (the "Proposed Rule") under the Investment Advisers Act of 1940 (the "Advisers Act"), that would make it unlawful for an...more
On November 25, 2015, the Commodity Futures Trading Commission (the "Commission" or the CFTC) proposed a comprehensive set of new rules ("Regulation AT") that, if adopted, potentially would impose many new obligations on most...more
On November 16, 2015, the Securities and Exchange Commission (SEC) sued an investment adviser, Virtus Investment Advisers, Inc., who had hired another adviser, F Squared Investments, Inc., to sub-advise certain mutual funds...more
Every five years, the US Department of Commerce's Bureau of Economic Analysis (BEA) conducts a survey concerning the extent of investment abroad by US individuals and entities (US persons). In the past, only US persons...more
The China Securities Regulatory Commission (CSRC) is soliciting public comment on proposed rules (Interim Measures) that would open Chinese futures markets to direct trading by non-Chinese persons apparently for both...more
In this issue:
- Bylaw of Delaware Corporation Providing for Exclusive Forum in North Carolina Upheld
- FINRA Board to Consider Rule Proposals Regarding Private Trading Platforms
- CBOE and C2 in...more
9/15/2014
/ AIFM ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Banks ,
Bitcoin ,
CBOE ,
CFTC ,
Commodity Pool ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
CPO ,
Cross-Border ,
Exclusive Jurisdiction ,
False Claims Act (FCA) ,
Financial Industry Regulatory Authority (FINRA) ,
Forum ,
ISDA ,
JOBS Act ,
Jurisdiction ,
Over The Counter Derivatives (OTC) ,
Regulation M ,
Regulation Z ,
Securities and Exchange Commission (SEC) ,
Security-Based Swaps ,
Swap Dealers ,
Swaps ,
UK
Registered investment companies that pursue alternative investment strategies (also referred to as "liquid alts") are a relatively new form of offering for investment managers accustomed to operating private investment funds....more
It is well-known that high-profile jurisdictions such as California and New York City have in certain instances placed lobbyist registration requirements on investment managers that solicit investment advisory business from...more