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SEC Cost-Benefit Analysis: A New Face and a New Role

Under the Trump administration, the Securities and Exchange Commission is in the process of revamping its approach to the cost-benefit analysis it performs in support of its regulatory actions. These changes are being spurred...more

New SEC Management Boldly Charts New Course

A shift in leadership at the Securities and Exchange Commission often brings significant changes in regulatory priorities and enforcement approaches. As anticipated in our firm’s EO Watch alert, “Immediate Practical...more

SEC Deep-Sixes Its Expanded “Dealer” Definition

Last year, the Securities and Exchange Commission amended its definition of “dealer” to require broker-dealer registration by some persons or entities previously considered securities “traders” not subject to such...more

Funds Not Caged by SEC Names Rule Amendments: Roaming Room Remains

The SEC recently adopted amendments to its investment company “names” rule that apply to most SEC-registered funds, including underlying funds in which registered insurance company separate accounts invest....more

New Procedures for Mutual Fund and Insurance Product SEC Filings

In Release No. 33-10618 (Mar. 20, 2019), the SEC adopted amendments (the “Amendments”) that consolidate, conform, and otherwise refine numerous requirements applicable to filings with the agency. ...more

Dodd-Frank Rollback Benefits Insurers

Marketing Private Life Insurance Separate Accounts to Smaller Banks - Subject to certain exceptions, the so-called “Volcker rule” provisions of the Dodd-Frank Act and regulations thereunder (collectively, the Volcker Rule)...more

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