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SEC Proposes to Require Reporting of Large Security-Based Swap Positions

The Securities and Exchange Commission on February 4, 2022 published in the Federal Register its proposed new Rule 10B-1 under the Securities Exchange Act of 1934, together with a related form, Schedule 10B. The SEC had voted...more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - February 2021

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

Registered and Exempt Market Participants May Need to Plan Ahead to Take Action Early in 2021 to Address CFTC and NFA Rule and...

During the course of 2019 and 2020, the Commodity Futures Trading Commission and the National Futures Association (NFA, the self-regulatory organization for the U.S. futures and swaps industry) have been hard at work amending...more

Analysis of SEC’s Proposal to Update the Regulation of Funds’ Use of Derivatives and Other Transactions

The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a three-part rule proposal related to the use of derivatives and certain other transactions by registered investment...more

U.S. Treasury’s Benchmark TIC SHL Survey and Implications for Investment Managers

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

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - January 2019

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

Registered CPOs and CTAs: Prepare for June 30 Changes to NFA Forms PQR and PR

Beginning with the second quarter 2017 filings, registered commodity pool operators (CPOs) and commodity trading advisors (CTAs) (collectively, Registrants) will need to report financial information regarding their own...more

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

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

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

The U.S. federal securities laws and the rules of U.S. self-regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

The U.S. federal securities laws and the rules of U.S. self-regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

TIC B Forms Are Amended to Explicitly Cover U.S. Investment Managers

In January 2014, U.S. investment managers may experience increased reporting obligations as a result of recent changes to the Treasury International Capital ("TIC”) reporting system effective for certain reports regarding...more

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