Title

Investment Management Regulatory Update
Client Newsletter

Created date

4/19/2012

SEC Rules and Regulations

  • SEC Staff Responds to Form ADV Questions Regarding Exempt Adviser Reporting and Financial Industry Affiliations
  • SEC Staff Issues Guidance on Issues of Interest to Investment Advisers and Investment Companies
  • Upcoming Deadline for Compliance with Pay-to-Play Rule’s Prohibition on Payments to Certain Third-Party Solicitors

Industry Update

  • The STOCK Act Is Enacted, Banning Insider Trading by Government Officials
  • FSOC Adopts Final Rule on Designation of Systemically Important Nonbank Financial Companies and the Federal Reserve Proposes Rule on Whether Companies Are “Predominantly Engaged in Financial Activities”
  • CFTC Adopts Swap Clearing Documentation, Timing and Risk Management Rules
  • SEC Enters Into Memoranda of Understanding with Cayman Islands and European Regulatory Counterparts

Litigation

  • ICI and Chamber of Commerce Challenge CFTC Amendments Restricting the Exclusion from CPO Registration for Advisers to RICs
  • SEC Charges Two Investment Advisers and a Broker-Dealer with Fraud for Misleading Fund Investors in connection with Secondary Market Trading of Pre-IPO Shares
  • U.S. Supreme Court Holds that the Section 16(b) Short-Swing Liability Statute of Limitations is Not Tolled by an Insider’s Failure to File a Section 16(a) Disclosure Report