The staff of the SEC’s Division of Investment Management (the “Staff”) granted no-action relief for the implementation of an adjustment in the fee paid by a mutual fund’s adviser to the fund’s subadviser, without shareholder...more
At a meeting held on July 23, 2014, the SEC voted 3-2 to adopt amendments (the “Amendments”) to various regulatory requirements affecting money market funds (“MMFs”). The Amendments, which are set forth in SEC Release No....more
The Securities Industry and Financial Markets Association (SIFMA) issued a memorandum (the “Memorandum”) with guidance for registered broker-dealers and investment advisers on various non-exclusive means of verifying an...more
The staff of the SEC’s Division of Investment Management issued IM Guidance Update No. 2014-7 (the “Guidance Update”) to provide guidance on how Rule 206(4)-2 under the Investment Advisers Act of 1940 (the “Custody Rule”)...more
The SEC settled administrative proceedings against an investment adviser, Paradigm Capital Management, Inc. (the “Adviser”), and Candace King Weir, the Adviser’s principal owner (the “Principal”), over violations of the...more
The SEC settled public administrative proceedings against TL Ventures Inc., a venture capital fund adviser (the “VC Fund Adviser”) and Penn Mezzanine Partners Management, L.P. (the “Private Fund Adviser” and with the VC Fund...more
The staff of the SEC’s Division of Investment Management (the “Staff”) issued IM Guidance Update No. 2014-4 discussing how a registered adviser or its investment advisory representatives (“IARs”) may use public commentary...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) sent a letter to advisers that have not yet been examined by the SEC as part of an initiative to examine a significant percentage of them, with a focus on...more
The SEC settled public administrative proceedings against Navigator Money Management (the “Adviser”), a registered investment adviser, and its principal, Mark A. Grimaldi (the “Principal”), over advertisements in newsletters...more
The Securities and Exchange Commission (the “SEC”) and Department of Labor (“DOL”) reached settlements with Western Asset Management (the “Adviser”), a registered investment adviser and subsidiary of Legg Mason Inc., under...more
The Staff of the SEC’s Division of Investment Management issued IM Guidance Update 2014-1 which suggests risk management measures and related communications with fund boards that fund advisers may want to consider in view of...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced the 2014 examination priorities (the “Announcement”) for its National Examination Program (the “NEP”). The priorities are organized according to...more
The SEC settled public administrative proceedings against Merrill, Lynch, Pierce, Fenner & Smith Inc. (the “Sponsor”) relating to the structuring and marketing of three collateralized debt obligations (“CDOs”) and separately...more
The SEC issued an Order (the “Order”) instituting administrative and cease-and-desist proceedings against Ambassador Capital Management, LLC (the “Adviser”) and the portfolio manager (the “Portfolio Manager”) for a prime...more
An SEC-registered adviser (the “Adviser”) was granted exemptive relief pursuant to Rule 206(4)-5 (the “Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) from the Rule’s two-year prohibition on receiving...more
The SEC settled public administrative proceedings against a registered investment adviser (the “Adviser”) over (i) its exercise of discretion in valuing securities held by a privately offered fund the Advised managed (the...more
The Investor as Purchaser Subcommittee (the “Subcommittee”) of the SEC’s Investor Advisory Committee (the “Committee”) issued two principal recommendations (the “Recommendations”) regarding SEC adoption of a uniform standard...more