On March 23, 2020, in response to business disruptions caused by the spread of the coronavirus (“COVID-19”), the Securities and Exchange Commission (“SEC”) issued an exemptive order (the “Order”) under the Investment Company Act of 1940 (“1940 Act”) granting registered investment companies and insurance company separate accounts registered as

On March 23, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced that it will conduct its examinations of SEC registrants through correspondence, unless it is absolutely necessary to be on-site. On the same day, the co-directors of the Division of Enforcement issued a statement underscoring the importance of maintaining and following corporate

Like all of us, the SEC and its staff are moving rapidly to address changes to normal procedures required in the face of COVID-19. In response to questions recently raised by the Investment Advisers Association (IAA) on behalf of its members, the SEC staff clarified its expectations with respect to certain aspects of the Custody

On March 13th, the SEC announced that it is extending certain filing deadlines for investment advisers and registered funds that have been affected by COVID-19. Boards of registered funds that may find it challenging to travel to meetings also received temporary relief from in-person meeting requirements under the Investment Company Act. We analyze

Cybersecurity has been a key priority for the SEC and its Office of Compliance Inspections and Examinations (OCIE) in recent years. The OCIE regularly releases publications addressing cybersecurity risks and practices, including eight risk alerts related to cybersecurity since 2012.

In the latest example, OCIE recently published its Cybersecurity and Resiliency Observations Report, describing 34

The Securities and Exchange Commission (SEC) proposed amendments to both the advertising rule and the cash solicitation rule under the Investment Advisers Act of 1940 (the “Advisers Act”) on November 4, 2019. Neither rule — adopted in 1961 and 1979, respectively — has been amended significantly since it was adopted, although the SEC and its