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SEC Grants One-Year Exemption from New Short Sale Reporting Requirements

On February 7, 2025, the SEC issued a one-year exemption from compliance with new Rule 13f‑2 under the Securities Exchange Act of 1934 and related reporting on new Form SHO. The SEC adopted Rule 13f-2 and the Form SHO...more

SEC Staff Provides Guidance on Issues Related to Website Posting Requirements

On January 16, 2025, the staff of the Disclosure Review and Accounting Office of the SEC’s Division of Investment Management issued an Accounting and Disclosure Information (ADI) publication to highlight issues the SEC staff...more

SEC Settles Enforcement Proceedings Against Quantitative Hedge Fund Manager for Alleged Algorithmic Model Vulnerabilities

On January 16, 2025, the SEC announced the settlement of administrative proceedings brought against a hedge fund manager that used algorithmic investment models to provide investment advice to its private fund and separately...more

SEC Re-Proposes New Rule Governing Funds’ Use of Derivatives

On November 25, 2019, the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) re-proposed a new exemptive rule under the Investment Company Act of 1940, as amended (the “1940 Act”)—Rule 18f-4 (the...more

Investment Services Regulatory Update - December 2019

New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes Rule Changes for Proxy Advisory Firms – On November 5, 2019, the SEC issued a release proposing amendments to the federal proxy rules...more

SEC Staff Issues Form CRS FAQs

On November 26, 2019, the staff of the SEC’s Division of Investment Management and Division of Trading and Markets issued guidance in the form of frequently asked questions (FAQs) relating to the requirements of Form CRS,...more

Remarks of Dalia Blass at the ALI CLE 2019 Conference on Life Insurance Company Products

On November 7, 2019, Dalia Blass, Director of the SEC’s Division of Investment Management, delivered the keynote address at the annual ALI CLE Conference on Life Insurance Company Products. Her remarks primarily focused on...more

SEC Extends Temporary Relief for MiFID II-Compliant Research Payments

On October 26, 2017, the SEC staff issued a no-action letter providing relief to broker-dealers that provide research that constitutes “investment advice” under the Investment Advisers Act of 1940 to investment managers...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

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

Court Finds for Defendant Investment Adviser in Section 36(b) Excessive-Fee Case

On August 5, 2019, the U.S. District Court for the Central District of California found for the defendant, Metropolitan West Asset Management, LLC (MetWest), following a bench trial in an excessive fee case brought under...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

The SEC’s Variable Contract Summary Prospectus and Disclosure Enhancement Proposals—Synopsis and Areas for Industry Comment

I. Overview of the Summary Prospectus Proposal - In a long-awaited development, the Securities and Exchange Commission (SEC or Commission), on October 30, 2018, issued a proposal consisting of new rules and registration...more

SEC Proposes New Rule to Permit Certain ETFs to Operate without an Exemptive Order

I. Executive Summary - Overview - The Securities and Exchange Commission (the “Commission”) proposed Rule 6c-11 (the “Proposed Rule”) under the Investment Company Act of 1940, as amended (the “1940 Act”),1 if adopted,...more

Investment Services Regulatory Update - May 2018

SEC Proposes Amendments to Auditor Independence Rules to Address Certain Lending Relationships - Summary - On May 2, 2018, the SEC issued proposed amendments to its auditor independence rules concerning the...more

Investment Services Regulatory Update - January 2018

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - Division of Investment Management Staff Issues Liquidity Risk Management Program FAQs - On January 10, 2018, the staff of the SEC’s...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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