On May 5, 2023, the U.S. Securities & Exchange Commission filed its first enforcement complaint under Rule 22e-4 of the Investment Company Act of 1940, 17 C.F.R. § 270.22e-4 (the Liquidity Rule). The complaint was brought...more
5/11/2023
/ Enforcement Actions ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Funds ,
Liquidity ,
Liquidity Risk Management Rule ,
Open-Ended Fund Companies (OFCs) ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Violations
The Securities and Exchange Commission (SEC) recently adopted, in a 3-2 vote, rule and form amendments impacting proxy disclosures reporting on Form N-PX (the “amendments”).
The amendments that are applicable to mutual...more
11/14/2022
/ Corporate Governance ,
ETFs ,
Executive Compensation ,
Investment Companies ,
Investment Company Act of 1940 ,
Investment Funds ,
Proxy Season ,
Proxy Statements ,
Proxy Voting ,
Required Forms ,
Say-on-Pay ,
Securities and Exchange Commission (SEC)
On February 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed a package of new rules and amendments to enhance cybersecurity preparedness and improve cyber resilience of investment advisers and investment...more
2/11/2022
/ Comment Period ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cyber Threats ,
Cybersecurity ,
Disclosure Requirements ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Companies ,
Investment Company Act of 1940 ,
New Rules ,
Policies and Procedures ,
Proposed Rules ,
Public Comment ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
On December 15, 2021, the U.S. Securities and Exchange Commission (the “SEC”) voted, by a 3-2 vote, to propose money market fund reforms that would significantly impact the regulatory framework governing money market funds...more
12/22/2021
/ Comment Period ,
Financial Regulatory Reform ,
Form N-MFP ,
Investment Company Act of 1940 ,
Liquidity ,
Liquidity Fees ,
Money Market Funds ,
Proposed Amendments ,
Public Comment ,
Redemption Gates ,
Reporting Requirements ,
Rule 2a-7 ,
Securities and Exchange Commission (SEC) ,
Swing Pricing
On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more
11/25/2020
/ Amended Rules ,
Broker-Dealer ,
Derivatives ,
Exceptions ,
Internal Reporting ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Funds ,
Investors ,
Mutual Funds ,
New Regulations ,
Policies and Procedures ,
Popular ,
Recordkeeping Requirements ,
Registered Funds ,
Reporting Requirements ,
Repurchase Agreements ,
Risk Assessment ,
Risk Management ,
Rule 18f-4 ,
Rule 6c-11 ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Transactions ,
Stress Tests
On October 7, 2020, the Securities and Exchange Commission (the "SEC") adopted Rule 12d1-4 under (the "Rule") the Investment Company Act of 1940 (the "1940 Act") and related amendments designed to put in place a comprehensive...more
10/21/2020
/ Business Development Companies ,
Closed-End Funds ,
ETFs ,
ETMFs ,
Exemptive Relief ,
Form N-CEN ,
Fund of Funds ,
Insurance Contracts ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Management ,
Investment Trust Companies ,
Liquidity ,
Open-Ended Fund Companies (OFCs) ,
Registered Funds ,
Regulatory Requirements ,
Risk Management ,
Rule 12d1-4 ,
Securities and Exchange Commission (SEC) ,
Voting Securities
On April 21, 2020, the U.S. Securities and Exchange Commission (the “SEC”) voted to propose new Rule 2a-5 (the “Proposed Rule”) under the Investment Company Act of 1940 (the “1940 Act”) that, if adopted, would establish a...more
4/30/2020
/ Board of Directors ,
Business Development Companies ,
Comment Period ,
Fair Value Standard ,
Good Faith ,
Investment Adviser ,
Investment Companies ,
Investment Company Act of 1940 ,
Investment Management ,
Proposed Rules ,
Public Comment ,
Securities and Exchange Commission (SEC) ,
Valuation
As a result of upcoming increases in securities registration fee rates applicable to mutual funds, funds with fiscal year ends of July or August and net sales should consider accelerating their annual Rule 24f-2 filings....more
As a result of upcoming increases in securities registration fee rates applicable to mutual funds, funds with fiscal year ends of July or August and net sales should consider accelerating their annual Rule 24f-2 filings.
...more
On January 6, 2016, the staff (the “Staff”) of the SEC’s Division of Investment Management published guidance (the “Guidance”) containing the Staff’s views and recommendations relating to mutual fund distribution and...more
The SEC recently adopted amendments to the rules governing MMFs. Most particularly, the amendments (i) require institutional prime and institutional tax-exempt MMFs to use a floating net asset value as opposed to allowing...more