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ESG and SEC Enforcement in 2022
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Investment Management and Private Funds Roundtable: TALF 2020 and PPP Update
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Videocast: Asset management regulation in 2020 videocast series – SEC enforcement
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Podcast: Questions & Concerns About Documentation: A Conversation with Colin Adams, M-III Partners
SEC Loses in ALJ Case, DOL’s Latest Fiduciary Rule Put on Hold, and SEC Reconsiders AI and Custody Rule Proposals - Welcome to our July Regulatory Roundup, where we provide a quick look at the latest regulatory developments....more
SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more
The SEC’s new and proposed rules on cybersecurity and cyber-incident reporting will have a dual impact on private investment advisers and funds. First, the proposal by the SEC will impose cybersecurity related...more
As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more
In 2023, the Securities and Exchange Commission issued various proposed rules on regulatory changes that will affect SEC-registered investment advisers (RIAs). Since these rules are likely to be put into effect, RIAs should...more
Who may be interested: Registered Investment Companies, Investment Advisers - Quick Take: The Office of Information and Regulatory Affairs, a division of the Office of Management and Budget, recently issued the Fall 2023...more
In the October edition of our Public Company Watch, we cover key issues impacting public companies, including the SEC adopting rules modernizing beneficial ownership reporting and short sale reporting, and issuing new C&DIs...more
Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more
The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more
According to its Spring 2023 rulemaking agenda, the U.S. Securities and Exchange Commission (SEC) has delayed issuance of two sets of cybersecurity requirements that previously were expected to be finalized in April 2023. The...more
At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted unanimously to propose rule amendments to Regulation S-P (Proposed Rule) and published an accompanying release (Release). The Proposed...more
On March 15, 2023, the Securities and Exchange Commission (“SEC”) proposed a new rule concerning cybersecurity risk management as well as updates to Regulations S-P and SCI (Systems Compliance Integrity).[1] With these...more
SEC Rules and Amendments - Liquidity Rule Amendments: Interval Funds to the Rescue? On November 2, 2022, the Securities and Exchange Commission (SEC) voted to propose significant amendments to Rule 22e-4 under the...more
Last week, the Securities and Exchange Commission (the “SEC”) proposed amendments to Regulation S-P (the “Proposal”) that would require registered investment advisers (“RIAs”), broker-dealers (“BDs”), investment companies...more
The 2023 Report on FINRA’s Examination and Risk Monitoring Program was published on Jan. 10, 2023. In a statement accompanying the Report, Greg Ruppert, executive vice president of FINRA’s Member Supervision organization,...more
In 2023, Registered Investment Advisers (“RIAs”) who are registered with the Securities and Exchange Commission (“SEC”) should be prepared for regulatory changes. These include proposed changes to rules governing RIA...more
The Biden Administration released its Fall 2022 regulatory agenda (Regulatory Agenda) on Jan. 4, 2023. In it, the administration outlined regulations aimed at cybersecurity requirements for government contractors, the...more
What is in store for Privacy and Cybersecurity in 2023 - As the year ends, we offer this special edition with predictions for 2023 from each member of the Cyber Bits Partner Committee. Regardless of what happens in 2023, we...more
Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of inadequacies in their identity theft red flag policies and...more
Final comments were due last week to the Securities and Exchange Commission (SEC)’s proposed cybersecurity risk management rules for registered investment advisers, registered investment companies and business development...more
Following closely on its proposal for substantial new cybersecurity requirements for investment advisers and registered investment companies, the Securities and Exchange Commission (SEC) unveiled a new slate of proposed...more
After many years of signaling potential expansion of cybersecurity rules, the Securities and Exchange Commission (SEC) has issued in the past month two new sets of proposed rules governing cybersecurity. The more recent set...more
On March 9, 2022, the Securities and Exchange Commission ("SEC") proposed rules that would require public companies to make prescribed cybersecurity disclosures. The proposed rules would "strengthen investors' ability to...more
Our Privacy, Cyber & Data Strategy and Investment Management, Trading & Markets Teams review the Securities and Exchange Commission’s potentially transformative proposed rules that would require registered investment...more
On 9 February 2022, the U.S. Securities and Exchange Commission (the SEC) proposed new rules and amendments to existing rules (together, the Proposed Rules) addressing cybersecurity risk management under the Investment...more