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Registered Investment Companies (RICs)

Latham & Watkins LLP

SEC Targets Investment Advisers for Misstatements and Compliance Failures

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Three recent enforcement actions highlight the risks of failing to adhere to representations made to investors regarding ESG and biblically responsible investing strategies....more

Troutman Pepper Locke

Investment Management Update - Q3 2024

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On August 28, the U.S. Securities and Exchange Commission (SEC) adopted amendments to certain registered investment companies (funds) reporting requirements. The SEC originally proposed the amendments on November 2, 2022....more

Cozen O'Connor

Summarizing the SEC’s 2025 Examination Priorities Report, Part 2

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In the second part of this legal update series, we summarize the key takeaways from the Division of Examinations’ (Division) 2025 priorities report released on October 21, 2024. The Division remains focused on mainstays like...more

Goodwin

2025 SEC Exam Priorities for Investment Advisers and Registered Investment Companies

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On October 21, the Securities and Exchange Commission’s (SEC’s) Division of Examinations (Division) released its examination priorities for 2025, outlining the key topics the Division plans to focus on in the upcoming fiscal...more

Morrison & Foerster LLP

SEC Division of Examinations 2025 Exam Priorities – a Focus on Artificial Intelligence, Private Funds, and Cybersecurity

On October 21, 2024, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) announced its 2025 Examination Priorities (the “2025 Priorities”), highlighting areas that it expects to target...more

Seward & Kissel LLP

SEC Division of Examinations Releases its 2025 Examination Priorities

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The staff of the SEC Division of Examinations (Staff) recently released its 2025 examination priorities. The timing of the release aligns with the start of the SEC’s fiscal year to provide transparency and inform participants...more

K&L Gates LLP

Checked Swing—SEC Does Not Adopt "Swing Pricing" or a "Hard Close" for Now, but Only Provides Liquidity Guidance and Amendments to...

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EXECUTIVE SUMMARY On 28 August, 2024, the Securities and Exchange Commission (SEC) adopted amendments to reporting forms for registered investment companies (funds) that will (1) require funds to file monthly (rather than...more

Seward & Kissel LLP

SEC Enforcement Action Rundown

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Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of enforcement actions relating to recordkeeping failures,...more

Sullivan & Worcester

SEC Adopts Amendments to Form N-PORT and Form N-CEN Reporting Relating to Liquidity Risk Management; Issues Guidance on Open-End...

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On August 28, 2024, the Securities and Exchange Commission (“SEC”) adopted amendments to reporting requirements on Forms N-PORT and N-CEN that apply to certain registered investment companies, including registered open-end...more

Seward & Kissel LLP

1% Stock Buy Back Tax; Little Relief for Issuers Under Final Tax Regulations

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The U.S. Treasury finalized regulations (the “Regulations”), providing rules for public companies subject to the 1% excise tax on certain redemptions of their publicly traded stock (the “Stock Repurchase Excise Tax”). The...more

Walkers

Update on changes to the beneficial ownership regime in the Cayman Islands

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Changes to the beneficial ownership regime took effect on 31 July 2024 and enforcement relating to the new requirements is suspended until early 2025. Many entities that previously had few or no obligations will have to...more

Seward & Kissel LLP

SEC Releases Spring 2024 Regulatory Agenda, Plans to Re-Propose Several Key Rules

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The Office of Information and Regulatory Affairs, a division of the Office of Management and Budget, released its Spring 2024 Unified Agenda of Regulatory and Deregulatory Actions, which includes short- and long-term...more

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Foley Hoag LLP

Reminder: New Say-on-Pay Disclosures for Institutional Investment Managers Now Effective

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The Securities and Exchange Commission (“SEC”) adopted amendments to Form N-PX on November 2, 2022. Previously, Form N-PX applied solely to registered investment companies (i.e., mutual funds, exchange-traded funds and...more

Akerman LLP

Initial Form N-PX Filing Deadline for Institutional Investment Managers Approaching

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Investment managers required to file Form N-PX pursuant to Rule 14Ad-1 of the Securities Exchange Act of 1934, as amended, will face their initial Form N-PX filing deadline on August 31, 2024. Although the filing obligation...more

Paul Hastings LLP

SEC Adopts Amendments To Regulation S-P

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

Eversheds Sutherland (US) LLP

Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

Seward & Kissel LLP

SEC Releases Materials on T+1 Settlement Cycle Adoption in Advance of May Compliance Date

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Who may be interested: Registered-Investment Companies; Investment Advisers; Broker-Dealers - Quick Take: In May 2023, the SEC adopted several Rules and Rule amendments which, among other things, shorten the standard...more

WilmerHale

SEC Adopts New Rules That Will Require More Market Participants to Register as Dealers

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On February 6, 2024, by a vote of 3-2 along party lines, the Securities and Exchange Commission (the SEC or the Commission) adopted Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (the Exchange Act), which...more

Conyers

Conyers BVI Quarterly Corporate Update – Q3 2023

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Welcome to the latest edition of our Quarterly Corporate Update covering recent developments in the British Virgin Islands. Q3 of 2023 has been a busy quarter for the BVI office. Our corporate team continued to advise on...more

Goodwin

SEC EXAMS Division Announces 2024 Priorities Ahead of Schedule

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On October 16, 2023, the SEC’s Division of Examinations (EXAMS) published its exam priorities for 2024. The timing is notable, with the release coming several months ahead of the typical timeline and only eight months after...more

Morrison & Foerster LLP

U.S. SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the...more

McDermott Will & Emery

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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On October 10, 2023, the US Securities and Exchange Commission (SEC) adopted amendments to Sections 13(d) and 13(g) of the Securities Exchange Act of 1934, which among other things, accelerate the filing deadlines for...more

Seward & Kissel LLP

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

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Who may be interested: Registered Investment Companies, Investment Advisers. Quick Take: The SEC adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Exchange...more

Proskauer Rose LLP

SEC Adopts Amendments to Fund Names Rule

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On September 20, 2023, the Securities and Exchange Commission (the “SEC”) voted to adopt final amendments to modernize Rule 35d-1 of the Investment Company Act of 1940, as amended (the “1940 Act”). This rule, commonly...more

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