Investment Adviser Regulation

On October 7, 2020, the Securities and Exchange Commission (SEC) adopted a new fund of funds rule. New Rule 12d1-4 is designed to streamline and enhance the existing regulatory framework under which registered funds of funds have been offered. The new rule’s adoption is a recognition that fund of funds arrangements provide an efficient

On March 30, 2020, the Securities and Exchange Commission (SEC) issued a no-action letter stating that the staff of the SEC’s Division of Trading and Markets would not recommend enforcement actions against broker-dealers that treat unsecured receivables related to bank sweep accounts as an allowable asset that is not deducted from net worth

On March 25, 2020, the SEC issued exemptive orders replacing prior orders granting temporary relief from certain provisions of the Investment Advisers Act of 1940 (the “Advisers Act”) and the Investment Company Act of 1940 (the “1940 Act”). The SEC said that it has been monitoring developments related to the effect that COVID-19 and related

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

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

The California Consumer Privacy Act (CCPA) imposes sweeping obligations on a diverse array of businesses, but investment advisers subject to Regulation S-P (adopted pursuant to the federal Gramm-Leach-Bliley Act (GLBA)) are treated somewhat differently. The CCPA does not provide a blanket exemption for investment advisers with retail clients, although the CCPA’s exception for personal information