News & Analysis as of

Securities and Exchange Commission (SEC) Life Insurance Investment Management

Carlton Fields

Expect Focus - Volume II, May 2025

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Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more

Carlton Fields

Expect Focus - Volume IlI, September 2024

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Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

Carlton Fields

Expect Focus - Volume II, May 2024

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Last Lap in SEC RILA Rulemaking Critical Unresolved Issues - Congress directed the SEC to adopt a new registration statement for registered indexed annuities (RILAs) by the end of June. Several months ago, the SEC...more

Eversheds Sutherland (US) LLP

SEC grants no-action relief to delay payment from variable insurance contracts to protect vulnerable adults in cases of suspected...

Recently, in response to a request from the Committee of Annuity Insurers, the staff in the Chief Counsel's Office of the Securities and Exchange Commission's (SEC) Division of Investment Management issued a no-action letter...more

Carlton Fields

Expect Focus - Volume III, September 2023

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Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Carlton Fields

Reg BI Compliance Countdown: T-Minus Six Months

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As the June 30, 2020, compliance date approaches, broker-dealers are taking steps to implement Regulation Best Interest (Reg BI), which establishes a new standard of conduct when making recommendations to retail customers of...more

Vedder Price

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

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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

Carlton Fields

Multiple Plaintiffs Take Shot at SEC Regulation Best Interest

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The Securities and Exchange Commission’s Regulation Best Interest faces a bumpy road in the wake of recent lawsuits challenging the appropriateness and effectiveness of the rule....more

Carlton Fields

Unpacking the SEC’s Regulation Best Interest Package

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On June 5, 2019, the SEC adopted a four-part regulatory package that includes: new Regulation Best Interest (Reg. BI), the related “Relationship Summary” disclosure form (Form CRS), and two interpretations of the Advisers...more

Carlton Fields

Use of Non-Binding SEC Staff Guidance Called Into Question

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Recent moves by the SEC could signal a shift away from the use of non-binding guidance in the form of no-action letters or other types of compliance and interpretive information that the SEC staff frequently publishes....more

Carlton Fields

SEC Lightens Legal Load of Mutual Fund Directors

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The SEC staff now says that mutual fund directors can rely on chief compliance officer certifications in determining compliance with board procedures required by SEC exemptive Rules 10f-3, 17a-7, and 17e-1 under the...more

Ballard Spahr LLP

Investment Management Update

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Here in is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry....more

Vedder Price

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

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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

Carlton Fields

Expect Slower SEC Processing of Investment Company Filings

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The SEC has reported to Congress that it expects the Division of Investment Management (IM) to provide comments at a slower pace during the 2018 and 2019 fiscal years....more

Carlton Fields

SEC Sidelines Funds Focused on Cryptocurrencies

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In a January 18 letter to two of the fund industry’s leading advocacy groups, the staff of the SEC’s Division of Investment Management advised fund sponsors not to initiate registration of funds that intend to invest...more

Carlton Fields

Expect Focus - Volume IV, December 2017

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EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

Treasury Department Urges SEC to Act on Life Company Products

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The U.S. Department of the Treasury published an October 2017 report, "A Financial System That Creates Economic Opportunities — Asset Management and Insurance" in response to President Trump’s Executive Order 13772 on "Core...more

Carlton Fields

Expect Focus - Volume III - September 2017

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EXPECTFOCUS® is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

SEC Scrutinizes Multi-Manager Arrangements

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Many mutual funds implement their investment strategies through "multi-manager" (also called "manager of manager") arrangements, particularly funds used to support variable life insurance and annuity products. Among other...more

Carlton Fields

SEC Investor Advocate’s 2018 Objectives Target Key Issues for Life Insurers

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On June 29, the SEC’s Office of the Investor Advocate released a report that prioritizes addressing the inconsistency in the standard of care applicable to broker-dealers (a suitability standard) versus investment advisers (a...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

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1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

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