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Reviewing the Industry Groups’ Opening Brief Challenging the Private Funds Rules

On November 1, 2023, the industry groups (the Petitioners) challenging the new Private Fund Adviser Rules filed in the US Court of Appeals for the Fifth Circuit their opening brief (the Brief) setting forth their legal...more

SEC Files First Enforcement Complaint Under Liquidity Rule

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

Delaware Adopts Control Share Acquisition Statute for Registered Closed-End Funds and Business Development Companies Organized In...

The state of Delaware recently amended the Delaware Statutory Trust Act to adopt a control share acquisition statute (the “Control Share Statute”) as an anti-takeover defense. Beginning on August 1, 2022, the effective date...more

SEC Enforcement Weighs in on Variable Annuity Exchanges for the First Time

After years of relative silence related to variable annuity exchanges on the regulatory front, the U.S. Securities and Exchange Commission announced last week settled charges against RiverSource Distributors, Inc...more

Lawsuits Targeting SPACs as Unregistered Investment Companies

Within the last two weeks, a group of plaintiffs’ attorneys have filed derivative lawsuits in U.S. federal court in New York against three separate special purpose acquisition companies (“SPACs”) — Pershing Square Tontine...more

In First Published Appellate Decision Addressing Gartenberg Factors Since Jones v. Harris, U.S. Court of Appeals Rejects...

On March 30, 2020, 10 years to the day after the Supreme Court issued its decision in Jones v. Harris, 559 U.S. 335 (2010), the U.S. Court of Appeals for the Sixth Circuit issued the first published federal appellate decision...more

Not Dead Yet: Second Circuit Revives Private Rights of Action Under Section 47(B) of the Investment Company Act of 1940

Since 2002, federal courts have refused to find that implied private rights of action exist under the Investment Company Act of 1940 (ICA). Last week, however, the United States Court of Appeals for the Second Circuit held...more

Another Court Grants Summary Judgment to Adviser In Section 36(B) Mutual Fund Excessive Fee Lawsuit Brought Under Subadvisory Fee...

In a newly unsealed decision, the federal district court in Manhattan granted summary judgment in favor of a mutual fund’s investment adviser in a lawsuit filed pursuant to Section 36(b) of the Investment Company Act of 1940....more

Second Circuit Affirms Pre-Discovery Dismissal of Section 36(b) Subadvisory Fee Comparison Complaint

On March 18, 2019, the U.S. Court of Appeals for the Second Circuit affirmed the dismissal prior to discovery of a complaint filed under Section 36(b) of the Investment Company Act of 1940. The Second Circuit’s decision is...more

Another Court Partially Denies Summary Judgment, Sends Case to Trial in Section 36(b) Excessive Fee Action

On October 25, 2018, Judge George Wu of the U.S. District Court for the Central District of California in Los Angeles largely denied an investment adviser’s motion for summary judgment in an action against Metropolitan West...more

Court Partially Denies Summary Judgment for Adviser in Section 36(b) Excessive Fee Action

On October 3, 2018, Judge Edgardo Ramos of the U.S. District Court for the Southern District of New York issued a decision that largely denied an investment adviser’s motion for summary judgment in an action filed against...more

Rejecting Subadvisory Fee Comparison, Federal District Court Enters Summary Judgment for Investment Adviser and Administrator in...

On March 9, 2018, the U.S. District Court for the Southern District of Ohio entered summary judgment for defendants in an action brought under Section 36(b) of the Investment Company Act of 1940. The plaintiffs in the action...more

Federal District Court Dismisses Mutual Fund Excessive Fee Lawsuit

On February 14, 2018, the U.S. District Court for the Southern District of New York in Manhattan issued a decision dismissing a complaint brought under Section 36(b) of the Investment Company Act of 1940, as amended, that...more

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