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Sullivan & Worcester

Deadline for Form 13F Filers for New Reporting Requirements on Executive Compensation Votes Rapidly Approaching

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The Securities and Exchange Commission adopted rule and form amendments that will require institutional investment managers who file Form 13F to use Form N-PX to report how they voted proxies on executive compensation (or...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

Seward & Kissel LLP

FinCEN Imposes New Reporting Requirements on LLCs and Other Entities

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The Corporate Transparency Act (the “CTA”), a set of new regulations being implemented by the Financial Crimes Enforcement Network (“FinCEN”), requires entities newly formed or registered to do business in the United States...more

McCarter & English, LLP

SEC Issues New Rules for Hedge Fund and Private Equity Disclosures

On May 3, the Securities and Exchange Commission approved a new rule that will require hedge fund advisers and private equity advisers to disclose more information to regulators on Form PF about their stability risks and...more

Goodwin

SEC Files First Enforcement Complaint Under Liquidity Rule

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On May 5, 2023, the U.S. Securities & Exchange Commission filed its first enforcement complaint under Rule 22e-4 of the Investment Company Act of 1940, 17 C.F.R. § 270.22e-4 (the Liquidity Rule). The complaint was brought...more

K&L Gates LLP

SEC's Division of Examinations Issues Risk Alert on Investment Adviser MNPI Compliance Issues

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In a Risk Alert issued on 26 April 2022 (the Risk Alert), the staff of the Division of Examinations (the Staff) of the Securities and Exchange Commission (SEC) described notable deficiencies relating to investment advisers’...more

Eversheds Sutherland (US) LLP

SEC proposes sweeping new private fund adviser rules and amendment to compliance rule affecting all registered investment advisers

On February 9, 2022, the Securities and Exchange Commission (SEC) proposed far-reaching new rules and rule amendments under the Investment Advisers Act of 1940, as amended (Advisers Act). The rules and amendments would...more

Goodwin

SEC Updates Regulatory Framework For Good Faith Determinations Of Fair Value

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On December 3, 2020, the U.S. Securities and Exchange Commission (the “SEC”) voted to adopt new Rule 2a-5 (the “Fair Value Rule”) under the Investment Company Act of 1940 (the “1940 Act”), which addresses the valuation...more

Goodwin

SEC Adopts New Regulatory Framework For Registered Fund Derivative Investments

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On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more

A&O Shearman

UPDATED: SEC Extends Sweeping Temporary Exemptions Granted to Funds to Comply with Voting, Reporting and Prospectus Delivery...

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In an Order dated March 25, 2020, the Securities and Exchange Commission extended the exemptions offered to investment companies, business development companies (BDCs) and investment advisers grappling with challenges to the...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - February 2020

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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

Dechert LLP

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

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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

Proskauer Rose LLP

The ERISA Litigation Newsletter - August 2016

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Editor's Overview - This month’s newsletter features an article on the DOL’s recently published interim final rule that increases penalties for notice and disclosure violations, which generally became effective on...more

Dechert LLP

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

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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

Akin Gump Strauss Hauer & Feld LLP

2015-16 Compliance Developments & Calendar for Private Fund Advisers

Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more

K&L Gates LLP

SEC Proposes New Reporting Requirements for Registered Funds

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On May 20, 2015, the Securities and Exchange Commission (“SEC”) proposed rules, forms and amendments under the Investment Company Act of 1940 (the “1940 Act”) and related regulations (together, the “Proposed Amendments”) that...more

Morrison & Foerster LLP

SEC Proposes Heightened Data and Reporting Rules for Funds and Advisers, Ponders New Rules on Derivatives and Leverage

At an open meeting of the Securities and Exchange Commission today, Chair Mary Jo White announced to enhance SEC reporting by investment companies and investment advisers. Data collection. The SEC proposed rules that...more

Morgan Lewis

SEC Proposes Rules Affecting Funds and Advisers

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Proposals would impose new disclosure requirements designed to enhance the SEC’s ability to monitor the industry. On May 20, the US Securities and Exchange Commission (SEC) unanimously approved proposals intended to...more

Dorsey & Whitney LLP

SEC Approves Proposals to Modernize and Enhance Reporting Regime for Registered Funds and Investment Advisers

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Yesterday, the Securities and Exchange Commission (“SEC”) unanimously approved two recommendations by the SEC’s Division of Investment Management to modernize and enhance the reporting regime for registered investment funds...more

Dechert LLP

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

Dechert LLP on

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

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