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Reporting Requirements Asset Management

Proskauer - Regulatory & Compliance

FRC Launches Consultation on UK Stewardship Code

On 11 November 2024, the Financial Reporting Council (“FRC”) launched a consultation with significant updates proposed to the UK Stewardship Code (the “Code”). The aims of the consultation are to streamline reporting...more

Farella Braun + Martel LLP

John Wick - What You Need To Know about the Corporate Transparency Act

Welcome to The Verdict: Estate Planning Through Film. In episode two, host Hons Yung is joined by Farella Braun + Martel's Greg LeSaint to discuss the movie John Wick and the Corporate Transparency Act (CTA). Greg breaks...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

Mintz

SEC Commissioner Peirce Critiques ESG Reporting Frameworks

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2 SEC Commissioner Peirce recently delivered a speech where she extensively criticized the recent emphasis on ESG among businesses, in particular the proliferation of mandatory ESG reporting frameworks. According to...more

Seward & Kissel LLP

CrowdStrike Outage and its Form PF Implications

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In May 2023, the Securities and Exchange Commission (the “SEC”) adopted amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, requiring, among other things,...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

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On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

SEC Compliance Consultants, Inc. (SEC³)

Top Tips for Updating Your 2024 Compliance Program

Every year compliance officers face the unenviable job of performing their compliance program's annual review under Advisers Act Rule 206(4)-7). An essential element of that review is updating the firm's compliance policies...more

Proskauer - Regulatory & Compliance

FCA Sustainability Disclosure Requirements Consultation Paper on the Extension to Portfolio Managers now published

The Financial Conduct Authority (the “FCA”) on 23 April 2024 has published its Consultation Paper CP24/8 (the “CP”) on the extension of its Sustainability Disclosure Requirements (“SDR”) to portfolio managers. This follows...more

Alston & Bird

Major Changes Coming to the Qualified Professional Asset Manager Exemption

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Our Employee Benefits & Executive Compensation and Investment Funds Teams break down the increased compliance requirements – and compliance costs – qualified professional asset managers (QPAMs) face under the Department of...more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

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What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

K&L Gates LLP

Not That FAR Away

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On 15 March 2024, the Financial Accountability Regime (FAR) came into effect for authorised deposit-taking institutions (ADIs), replacing the Banking Executive Accountability Regime (BEAR). Unlike the BEAR, application of the...more

Dechert LLP

Exploring DORA’s ICT Risk Requirements: Key Issues for Asset Managers

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DORA became law in December 2022 but provides for a grace period until 17 January 2025 for organisations to put in place the necessary measures to comply. The new rules will require engagement from both an operational and...more

K&L Gates LLP

SEC and CFTC Adopt Amendments to Form PF for Increased Disclosure

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Brief Overview - On 8 February 2024, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF (the Amendments), the confidential reporting form...more

K&L Gates LLP

SEC Expands "Dealer" Definition to Capture Liquidity Providers

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Introduction - On 6 February 2024, the US Securities and Exchange Commission (SEC) voted 3-2 to adopt two new rules that significantly expand the definitions of a “dealer” and “government securities dealer” in Sections...more

K&L Gates LLP

The US Corporate Transparency Act: Practical Considerations for Private Fund Sponsors as the Effective Date Approaches

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Earlier this year, the US Congress passed the Corporate Transparency Act (CTA). The CTA will require thousands of privately held US and non-US entities to report beneficial ownership to the US Treasury Department’s Financial...more

Pillsbury Winthrop Shaw Pittman LLP

California Bill Designed to Support Underrepresented Entrepreneurs Signed into Law

The bill requires certain venture capital companies to report demographic information about the founding team members of businesses in which they invested in the prior year. A “covered entity” must gather certain...more

K&L Gates LLP

The Corporate Transparency Act: Through a Family Office Lens

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The Corporate Transparency Act (CTA) is going into effect on 1 January 2024 and will mandate the disclosure of certain information related to beneficial owners and controllers of most US domestic entities and certain non-US...more

K&L Gates LLP

The SEC's New Private Fund Adviser Rules: A Guide to Compliance

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On 23 August, the US Securities and Exchange Commission adopted new rules and rule amendments that will impose substantial regulation on the management and operation of private funds by investment advisers. The Guide to...more

Proskauer Rose LLP

Taskforce on Nature-Related Financial Disclosures – New and Updated Nature Reporting Recommendations Published

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The NY Climate Week conference took place during the week of 18 September 2023, bringing together international leaders from business and governments. During the conference the Taskforce on Nature-related Financial...more

Cadwalader, Wickersham & Taft LLP

UK Financial Regulator Proposes Reporting Template to Enhance Transparency of Shareholder Voting

Amid ongoing scrutiny over proxy voting (particularly in relation to ESG-related resolutions), the UK’s financial regulator, the Financial Conduct Authority, has launched a consultation aimed at developing a vote-reporting...more

K&L Gates LLP

The SEC Significantly Expands the Scope of Form PF Reporting

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Introduction and Summary - On 3 May 2023, the Securities and Exchange Commission (SEC) approved amendments to Form PF (the Amendments), the confidential reporting form required to be filed by certain SEC-registered private...more

Dechert LLP

SEC Reopens Comment Period for Beneficial-Ownership Reporting Requirements Rule Proposal

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The U.S. Securities and Exchange Commission (the “SEC”) announced on April 28, 2023, that it has reopened the comment period for its February 2022 Modernization of Beneficial Ownership Reporting rule proposal (the “Proposed...more

Foley Hoag LLP

DOL Issues Proposed Amendment to QPAM Exemption

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The Department of Labor (“DOL”) recently issued a proposed amendment to prohibited transaction class exemption 84-14 (the “QPAM Exemption”). The QPAM Exemption permits an investment fund managed by a qualified professional...more

K&L Gates LLP

Q&A on the Proposed ESG Reforms for Registered Funds: Addressing the Potential Challenges Imposed and Comment Opportunities

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After much anticipation, the U.S. Securities and Exchange Commission (SEC) proposed significant, and potentially burdensome, disclosure and reporting requirements (the Proposed Amendments) for registered funds that use...more

Cadwalader, Wickersham & Taft LLP

EU Directive Targets 'Shell' Companies

On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more

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