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Alston & Bird

CFTC Guidance Clarifies Non-U.S. Person Status of Certain Offshore Trading Firms

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Our Investment Funds Team examines an interpretive letter from the Commodity Futures Trading Commission (CFTC) that may help to clarify when non-U.S. firms with U.S. contacts can be considered non-U.S. persons for...more

Perkins Coie

SEC Issues Guidance and Interpretation Aimed at Proxy Voting

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The U.S. Securities and Exchange Commission (SEC) held an open meeting on August 21, 2019, (the Open Meeting) and approved two items: (1) guidance regarding the proxy voting responsibilities of investment advisers under the...more

Womble Bond Dickinson

SEC Guidance Will Impact Roles of Proxy Advisers and Investment Advisers in Proxy Context

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Last week, the U.S. Securities and Exchange Commission (“SEC”) approved interpretative guidance relating to (i) the application of proxy rules to proxy advisory firms and (ii) the fiduciary role of investment advisers within...more

Faegre Drinker Biddle & Reath LLP

SEC Releases Guidance to Clarify Investment Advisers’ Proxy Voting Responsibilities and Interpretation of Proxy Rules to Voting...

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At an open meeting held on August 21, 2019 (the “Meeting”), the Commissioners of the Securities and Exchange Commission (SEC) issued guidance (the “Guidance”), by a 3-2 vote, to assist investment advisers when conducting...more

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