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SEC Adopts New Regulatory Framework For Use Of Derivatives By Registered Funds

On October 28, 2020, the SEC adopted a new regulatory framework for derivatives use by registered investment companies. New Rule 18f-4 applies to mutual funds other than money market funds, exchange-traded funds (ETFs),...more

Structured Thoughts - News For The Financial Services Community - October 2020

On October 28, 2020, the U.S. Securities and Exchange Commission (SEC) Chairman Jay Clayton, together with the directors of three SEC divisions, issued a joint statement relating to complex financial products. The statement...more

2019 SEC Regulatory Summary – Advisers And Funds

Before closing the books on 2019, registered investment advisers and funds should take a look back at the activity undertaken by the SEC and its staff in the past year and carefully consider steps to be taken to implement new...more

OCIE Publishes 2019 Enforcement Priorities

The SEC’s Office of Compliance Inspections and Examinations (OCIE) published its 2019 examination priorities on December 20, 2018. Although OCIE’s published priorities “provide a preview of key areas where OCIE intends to...more

New Exemptive Rule Could Lower Barriers to Entry for New ETFs

At an open meeting held June 28, 2018, the SEC voted unanimously to propose a new rule codifying exemptions to certain rules under the Investment Company Act. These exemptions have enabled the exchange-traded fund (ETF)...more

SEC Staff Raises Concerns Related to Cryptocurrency ETFs and Mutual Funds

On January 18, 2018, the Securities and Exchange Commission’s (SEC) Division of Investment Management broke its relative silence regarding the recent growth of cryptocurrencies and cryptocurrency-related products. While...more

SEC Releases Liquidity Rule FAQs

The staff of the SEC’s Division of Investment Management released this week a series of frequently asked questions (FAQs) regarding new Rule 22e-4 (the “Liquidity Rule”). The Liquidity Rule requires non-money market mutual...more

Investment Management Legal + Regulatory Update - August 2016

Regulation - Next on the SEC’s Regulatory Agenda: A Chief Valuation Officer? - First, the SEC required funds to designate a chief compliance officer. Then, the SEC proposed that funds designate a liquidity...more

It's Time To Loosen The Limitations On BDC Investors

Business development companies, which provide a growing and important alternative source of capital to smaller companies, face challenges raising money due to a quirk in the federal securities laws that limits how much mutual...more

Section 12(d)(1) and Business Development Companies

Business development companies (BDCs), which provide a growing and important alternative source of capital to smaller companies, face challenges raising money due to a quirk in the federal securities laws that limits how much...more

SEC Solicits Comments on Exchange-Traded Products

Citing significant growth in the size and scope of exchange-traded products (ETPs), on June 12, 2015, the SEC focused its attention on ETPs, including exchange-traded funds (ETFs), non-1940 Act pooled investment vehicles, and...more

FINRA Sanctions Member Firm for Failure to Deliver ETF Prospectuses

FINRA recently sanctioned a broker-dealer (the “Firm”) for failure to deliver prospectuses in connection with its sale of ETFs. FINRA also found that the Firm failed to implement a supervisory system reasonably designed to...more

Investment Management Legal + Regulatory Update -- December 2014

In This Issue: - Regulation ..SEC Chair’s Agenda Provides Glimpse of New Rules to Come ..The Results Are In: Investors Favor Additional Regulatory Protection ..SEC Declines to Approve Non-Transparent...more

ETF Mergers Possible Under Rule 17a-8

Can two affiliated ETFs merge in reliance on Rule 17a-8 under the Investment Company Act despite representations they made to obtain exemptive relief from the Commission? That’s the question addressed in a recent Guidance...more

Court Tosses ETF Securities Lending Fee Case

A federal district court in Tennessee dismissed a case brought by two union pension funds claiming that securities lending fees paid by an ETF to its adviser’s affiliate violated the adviser’s fiduciary duty under Section...more

Court of Appeals Upholds Dismissal of Case Alleging Disclosure Violations by Leveraged ETFs

The U.S. Court of Appeals for the Second Circuit upheld the dismissal by a lower court of investors’ claims that certain ETF prospectuses failed to adequately disclose the risk of significant losses over an extended period of...more

Investment Management Legal + Regulatory Update -- May 2013

In This Issue: Regulatory Updates - SEC Allows Limited Use of Social Media for Public Disclosure; Federal Reserve Board Publishes a Final Rule Specifying when Nonbank Firms are “Predominantly Engaged in...more

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