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SEC Staff Reverses Position on State Control Share Statutes for Closed-End Funds

On May 27, 2020, the staff of the SEC’s Division of Investment Management withdrew previously issued guidance addressing the intersection between state control share acquisition statutes (control share statutes) and the...more

Investment Services Regulatory Update - September 2019

New Rules, Proposed Rules, Guidance and Alerts - GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Improving Fund Principal Risks Disclosure - On September 9, 2019, the Disclosure Review and Accounting Office...more

FINRA Issues Supplemental Guidance on Giving Credit for Extraordinary Cooperation

On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which FINRA awards credit for providing "extraordinary cooperation" during an...more

SEC Staff Issues No-Action Letter Extending Existing Multi-Manager Exemptive Relief to Non-Wholly-Owned Affiliated Sub-Advisers

On July 9, 2019, the staff of the SEC’s Division of Investment Management issued a no-action letter to the BNY Mellon family of funds and BNY Mellon Investment Adviser, Inc. (collectively, BNYM) stating that the staff would...more

Investment Services Regulatory Update - March 2019

New Rules, Proposed Rules, Guidance and Alerts - NEW RULES - SEC Adopts Interim Final Rule Amending Timing Requirements for Filing Reports on Form N-PORT - On February 27, 2019, the SEC adopted an interim final rule...more

Investment Services Regulatory Update - January 2019

New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes New Fund-of-Funds Rule – On December 19, 2018, the SEC proposed new Rule 12d1-4 under the Investment Company Act of 1940, which, if...more

Investment Services Regulatory Update - October 2018

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS – SEC Staff No-Action Letter Allows Fund Boards to Rely on CCO Representations for Affiliated Transactions – In a no-action letter to the...more

Investment Services Regulatory Update - April 2018

New Rules, Proposed Rules, Guidance and Alerts - PROPOSED RULES - SEC Proposes Changes to Fund Liquidity Disclosure Requirements - On March 14, 2018, the SEC issued proposed amendments to the disclosure requirements...more

Investment Services Regulatory Update - October 2017

New Rules, Propsed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Extends No-Action Relief on Auditor Independence and the “Loan Provision” - On September 22, 2017, the staff of the SEC’s...more

Investment Services Regulatory Update - August 2017

On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more

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