News & Analysis as of

Form 13F Investment Management Reporting Requirements

Goodwin

New Proxy Voting Reporting Requirements For Investment Managers For 2023-24 Annual Meeting Season

Goodwin on

On November 2, 2022, the U.S. Securities and Exchange Commission (SEC) announced the adoption of amendments to Form N-PX and related rules to extend public company stockholder vote disclosure filing requirements beyond...more

Cooley LLP

New SEC Requirements for Form 13F Filers Effective July 1, 2024

Cooley LLP on

In late 2022, the Securities and Exchange Commission (SEC) adopted rule changes that will require institutional investment managers who file Form 13F to annually file a Form N-PX disclosing the manner in which they have voted...more

Morgan Lewis

New SEC Rule Requires 13F Filers to Track and Report on Proxy Voting

Morgan Lewis on

Institutional investment managers that file on Form 13F must make public filings on Form N-PX to report their “say-on-pay” proxy voting. Although the compliance date for this new filing requirement is not until August 2024,...more

Proskauer Rose LLP

SEC Proposes Monthly Short Sale Reporting Requirements: Aggregated Information to be Public; New Order Marking Requirements...

Proskauer Rose LLP on

The SEC recently proposed to require investment managers to report short sale information on a monthly basis if such activity exceeds certain thresholds, and to require broker dealers to begin to mark “buy to cover” trades...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes To Raise Form 13F Reporting Threshold From $100 Million to $3.5 Billion

On July 10, 2020, the Securities and Exchange Commission (SEC) voted 3-1 to approve proposed rules that, among other things, would raise the Form 13F reporting threshold for institutional investment managers (managers) from...more

Lowenstein Sandler LLP

SEC Proposes To Amend Form 13F Reporting Thresholds For Institutional Investment Managers

Lowenstein Sandler LLP on

On July 10, 2020, the Securities and Exchange Commission (SEC) proposed to raise the Form 13F reporting threshold for institutional investment managers from $100 million to $3.5 billion (the Proposal). Currently, investment...more

Goodwin

Financial Services Weekly Roundup: Gone Phishing – The SEC’s OCIE Addresses Ransomware Attacks

Goodwin on

In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Amendments to Update Form 13F

The Securities and Exchange Commission (SEC) has recently proposed to amend the reporting threshold and make certain other changes to Form 13F. It should be noted that this is the first time the reporting threshold would be...more

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