Regulators Tackle Board Effectiveness and Overdrafts
The UK Financial Conduct Authority (FCA) has published observations on good and poor liquidity risk management practices from its multi-firm review of wholesale trading (sell-side) firms in scope of the Investment Firms...more
The Securities and Exchange Commission (SEC) recently adopted amendments to the reporting requirements of Forms N-PORT and N-CEN and issued guidance related to registered open-end funds’ liquidity risk management programs...more
In our recent alert Loan Origination Under AIFMD2: A Guide, on loan origination under the revised Alternative Investment Fund Managers Directive (AIFMD2), we noted that the European Securities and Markets Authority (ESMA)...more
Closed-End Fund Activism Update - Activist investors continue to take large positions in closed-end funds and engage in disruptive activity that may be harmful to long-term shareholders of retail closed-end funds. This...more
The U.S. Securities and Exchange Commission and its staff recently have taken a series of regulatory actions regarding the implementation of the new liquidity rule, including (1) a proposal to amend certain reporting and...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
On September 22, 2015, the Securities and Exchange Commission (“SEC”) proposed a new rule and amendments to rules and reporting forms under the Investment Company Act of 1940 (the “1940 Act”), designed to standardize...more
SEC Updates Compliance and Disclosure Interpretations for Legacy Deals - On September 16, the SEC released its updated compliance and disclosure interpretations for the rules adopted under Regulation AB, the Securities...more
Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more