News & Analysis as of

Securities Exchange Act of 1934 Investment Management

Mayer Brown Free Writings + Perspectives

SEC Charges Eleven Institutional Investment Managers with Reporting Failures

On September 17, 2024, the Securities and Exchange Commission announced cease-and-desist proceedings against eleven institutional investment managers for failure to file reports required by the Securities Exchange Act of...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

K&L Gates LLP

US Asset Management Regulatory Year in Review 2023

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It is a dramatic understatement to describe 2023 as a busy year in the United States for asset management regulation. With 24 rules adopted and 18 new rules or rule amendments proposed, the US Securities and Exchange...more

Seward & Kissel LLP

SEC Adopts Gross Short Position and Activity Reporting by Institutional Investment Managers

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On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted new Rule 13f-2 (the “New Rule”) under Section 13(f)(2) of the Securities Exchange Act of 1934 (the “Exchange Act”), as well as related Form SHO....more

Dechert LLP

SEC Adopts Rules on Short Sales and Securities Lending

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The Securities and Exchange Commission on October 13, 2023, adopted two new rules under the Securities Exchange Act of 1934 expanding reporting requirements for securities lending and short sales and amending rules regarding...more

Paul Hastings LLP

SEC Adopts Rules Enhancing Short Sale Disclosures

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On October 13, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted final rules requiring the reporting and disclosure of short sale trade data information. New Rule 13f-2 implements new obligations on...more

A&O Shearman

Investment Adviser Fined $1.4 Million For Failure To Disclose SPAC Conflicts

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On May 31, 2023, the United States Securities and Exchange Commission (SEC) fined a New York investment adviser (Investment Adviser) $1.4 million for allegedly failing to disclose conflicts of interest regarding special...more

Pullman & Comley, LLC

Congress Enacts Statute Exempting “M&A Brokers” From Registration as Brokers or Dealers

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Effective March 29, 2023, certain small business brokers will be exempted from registering with the Securities and Exchange Commission (the SEC). The new law was signed into effect on December 29, 2022, as part of the...more

Seward & Kissel LLP

Memo to Clients 2023 - Annual Reminders

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This Memorandum is intended to remind you of certain U.S. annual requirements that may be applicable to your business and is divided into five sections. All investment advisers (whether or not registered with the Securities...more

Stinson LLP

SEC Staff Posts Conflicts of Interest Guidance for Broker-Dealers and Investment Advisers

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On August 3, 2022, the Securities and Exchange Commission (SEC) staff published a Q&A-Styled Bulletin focused on conflicts of interest under the Investment Advisers Act of 1940 (Advisers Act) and Regulation Best Interest (Reg...more

Alston & Bird

Investment Management, Trading & Markets Updates – August 2021

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SEC Increases Threshold for “Qualified Clients” Exemption Under Section 205-3 of the Investment Advisers Act of 1940 - On June 17, 2021, the Securities and Exchange Commission (SEC) announced that it will raise the monetary...more

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