The Securities and Exchange Commission recently adopted significant changes to Rule 35d-1 under the Investment Company Act of 1940 (Names Rule), as well as certain forms and disclosure requirements on September 20, 2023...more
12/6/2023
/ Derivatives ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Form N-PORT ,
Investment ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Portfolios ,
Notice Requirements ,
NSMIA ,
Proposed Amendments ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC)
On September 20, 2023, the U.S. Securities and Exchange Commission, by a vote of four to one, adopted amendments to the current rule regarding registered fund names, as well as certain forms and disclosure requirements. The...more
9/22/2023
/ Deceptive Intent ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Investment Company Act of 1940 ,
Investor Protection ,
Misleading Statements ,
New Amendments ,
Notice Requirements ,
Recordkeeping Requirements ,
Registered Funds ,
Securities and Exchange Commission (SEC)
Financial services providers that are subsidiaries of a non-U.S. parent (or that have received substantial direct investment from abroad) should evaluate whether they are required to file the Benchmark Survey of Foreign Direct...more
The U.S. Department of the Treasury (Treasury) announced on February 21, 2023, that TIC Form S — which Treasury has administered to collect data from financial institutions relating to aggregate purchases and sales of...more
Effective for reports as of November 2022 (i.e., those reports due in December 2022) and afterwards, the U.S. Department of Treasury (Treasury) has implemented important and significant changes to the reporting requirements...more
10/26/2022
/ Failure to Report ,
Fair Value Standard ,
Foreign Investment ,
Investment Adviser ,
Investment Management ,
Investors ,
Penalties ,
Reporting Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
Overview -
The U.S. Securities and Exchange Commission, by a vote of three-to-one, proposed for public comment on May 25, 2022, amendments to the rule governing naming conventions of funds1 subject to the U.S. Investment...more
In March 2022, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of U.S. ownership of foreign securities....more
In September and October 2020, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) is administering its next mandatory Benchmark Survey of Financial Services Transactions between U.S. Financial Services...more
10/14/2020
/ Asset Management ,
Banks ,
BE-180 ,
BEA ,
Benchmarks ,
Broker-Dealer ,
Collateralized Loan Obligations ,
Cross-Border Transactions ,
Data Collection ,
Financial Services Industry ,
Fund Managers ,
Surveys
In September and October 2020, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) will administer its next mandatory Benchmark Survey of Financial Services Transactions between U.S. Financial Services...more
9/20/2020
/ Aggregation Rules ,
Asset Management ,
Banks ,
BE-180 ,
BEA ,
Benchmarks ,
Broker-Dealer ,
Cross-Border Transactions ,
Electronic Filing ,
Filing Deadlines ,
Financial Services Industry ,
Foreign Investment ,
Insurance Industry ,
Surveys
The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures Trading...more
7/21/2020
/ Amended Regulation ,
CFTC ,
Covered Funds ,
Credit Funds ,
Exclusions ,
FDIC ,
Federal Reserve ,
Financial Regulatory Agencies ,
Foreign Excluded Funds ,
Investment Schemes ,
OCC ,
Ownership Interest ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Venture Capital ,
Volcker Rule ,
Wealth Management
Financial services providers that have non-U.S. affiliates should evaluate whether they are required to file the Benchmark Survey of U.S. Direct Investments Abroad (BE-10). Even if a firm has reported on BE-10 in the past,...more
4/29/2020
/ Asset Management ,
BEA ,
Benchmarks ,
Coronavirus/COVID-19 ,
Filing Deadlines ,
Financial Services Industry ,
Foreign Affiliates ,
Foreign Direct Investment ,
Form BE-10 ,
Multinationals ,
Pooled Investment Vehicles ,
Private Funds ,
Reporting Requirements ,
Surveys ,
Time Extensions ,
U.S. Commerce Department ,
Voting Shares
In August 2019, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of foreign residents’ holdings of U.S. issuers’ securities. The information will...more
7/22/2019
/ Benchmarks ,
Closed-End Funds ,
ETFs ,
Failure to Report ,
Federal Reserve ,
Foreign Investment ,
Foreign Residents ,
FRBNY ,
Hedge Funds ,
Index Funds ,
International Monetary Fund ,
Investment Funds ,
Investment Management ,
Investment Trust Companies ,
Money Market Funds ,
Mortgage REITS ,
Penalties ,
Pooled Investment Vehicles ,
Reporting Requirements ,
Securities ,
Surveys ,
TIC-SHL ,
U.S. Treasury
The U.S. Securities and Exchange Commission on June 18, 2019 adopted amendments to Rule 2-01(c)(1)(ii)(A) under Regulation S-X – the so-called “Loan Provision” (Final Rule). The Final Rule will become effective on October 3,...more
7/19/2019
/ Amended Rules ,
Auditor Independence ,
Auditors ,
Beneficial Owner ,
Investment Companies ,
Loan Provision ,
Loans ,
Registered Investment Companies (RICs) ,
Regulation S-K ,
Securities and Exchange Commission (SEC) ,
Significant Influence Test
The U.S. Securities and Exchange Commission (SEC) voted unanimously on May 2, 2018 to propose amendments to Rule 2-01(c)(1)(ii)(A) under Regulation S-X – the so-called “Loan Provision” (Proposal). Generally, the Loan...more
5/17/2018
/ Affiliates ,
Auditors ,
Audits ,
Beneficial Owner ,
Compliance ,
FASB ,
Lenders ,
Loans ,
No-Action Letters ,
Proposed Rules ,
Registered Investment Companies (RICs) ,
Regulation S-X ,
Securities and Exchange Commission (SEC) ,
Significant Influence Test
Financial services providers that are subsidiaries of a non-U.S. parent (or that have received substantial direct investment from abroad) should evaluate whether they are required to file the Benchmark Survey of Foreign...more
4/24/2018
/ BEA ,
Benchmarks ,
Filing Deadlines ,
Financial Services Industry ,
Foreign Corporations ,
Foreign Direct Investment ,
Form BE-12 ,
Multinationals ,
Parent Corporation ,
Pooled Investment Vehicles ,
Reporting Requirements ,
Subsidiaries ,
U.S. Commerce Department
The U.S. Department of the Treasury (Treasury) recently released a report examining the regulatory framework for the asset management and insurance industries (Report). The Report is the third in a series of four reports that...more
12/5/2017
/ Asset Management ,
CFTC ,
Department of Labor (DOL) ,
Derivatives ,
Dodd-Frank ,
Employee Retirement Income Security Act (ERISA) ,
Exchange-Traded Products ,
Federal Reserve ,
Fiduciary Rule ,
Financial Stability Board ,
FSOC ,
Insurance Industry ,
Investment Advisers Act of 1940 ,
Liquidity Risk Management Rule ,
Proposed Legislation ,
Proposed Regulation ,
Regulatory Burden ,
Retirement Plan ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
SIFIs ,
Stress Tests ,
Systemic Risk Buffer ,
U.S. Treasury ,
Volcker Rule
The U.S. Securities and Exchange Commission’s Division of Investment Management (SEC Staff) on September 22, 2017 extended indefinitely the effectiveness of no-action relief granted a year earlier with respect to the...more
10/6/2017
/ Auditor Independence ,
Auditors ,
Investment Management ,
Loan Agreements ,
Loans ,
No-Action Relief ,
Open-Ended Fund Companies (OFCs) ,
Registered Investment Advisors ,
Registered Investment Companies (RICs) ,
Regulation S-X ,
Securities and Exchange Commission (SEC)
The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more
11/30/2016
/ Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
FDIC ,
Financial Institutions ,
FSOC ,
Glass-Steagall Act ,
Liquidation ,
Presidential Elections ,
Shadow Banking ,
Too Big to Fail ,
Trump Administration ,
Volcker Rule
TIC SHC is a mandatory benchmark study commissioned by the Treasury and administered by the FRBNY every five years.3 The survey reviews holdings of foreign portfolio securities – including short- and long-term securities and...more
11/23/2016
/ Benchmarks ,
ETFs ,
Foreign Investment ,
Foreign Securities ,
FRBNY ,
Investment Management ,
Investment Trust Companies ,
Money Market Funds ,
Penalties ,
REIT ,
Reporting Requirements ,
Surveys ,
TIC SHC ,
U.S. Treasury
The U.S. Securities and Exchange Commission’s Division of Investment Management (the “SEC Staff”) last night issued a no-action letter (the “Relief”) to Fidelity Management and Research Company that provides guidance to...more
The Board of Governors of the U.S. Federal Reserve System (Board) recently proposed a rule (Proposed Rule) that will impact parties to any “qualified financial contract” (QFC), as described below, with a global systemically...more
The Bureau of Economic Analysis (BEA), in collaboration with the U.S. Department of the Treasury (Treasury Department) and the Federal Reserve Bank of New York, has proposed changes to certain cross-border investments that...more
For many U.S. asset managers and other financial services providers, the recent BE-10 Benchmark Survey of U.S. Direct Investment Abroad (BE-10) and the upcoming BE-180 Benchmark Survey of Financial Services Transactions...more
10/7/2015
/ Asset Management ,
BEA ,
Benchmarks ,
Cross-Border Transactions ,
Financial Institutions ,
Foreign Direct Investment ,
Foreign Investment ,
Form BE-10 ,
Reporting Requirements ,
Surveys ,
U.S. Commerce Department
In the fall of 2015, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) will administer its next Benchmark Survey of Financial Services Transactions between U.S. Financial Services Providers and Foreign...more
9/16/2015
/ Aggregation Rules ,
Asset Management ,
Banks ,
BE-180 ,
BEA ,
Benchmarks ,
Broker-Dealer ,
Cross-Border Transactions ,
Filing Deadlines ,
Financial Institutions ,
Foreign Financial Assets ,
Investment Adviser ,
Investment Funds ,
Surveys ,
U.S. Commerce Department
In recent months, both the U.S. Financial Stability Oversight Council (FSOC or Council) and the international Financial Stability Board (FSB) have taken actions signaling their continued interest in evaluating the potential...more
7/15/2015
/ Asset Management ,
Financial Institutions ,
Financial Stability Acts ,
FSB ,
FSOC ,
G-SIFI ,
Investment Fund Vehicles ,
Investment Funds ,
IOSCO ,
Leverage Ratio ,
Liquidity ,
OFR ,
SIFIs