Investment Management Regulatory Update - May 2016
Client Newsletter

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SEC Rules and Regulations

  • SEC Proposes Higher Net Worth Threshold for Qualified Clients under the Advisers Act
  • SEC Staff Grants No-Action Relief under Section 206(3) of the Advisers Act for Certain Purchases of Fractional Shares from Advisory Client Accounts by Advisers and Their Broker-Dealer Affiliates
  • SEC Staff Grants No-Action Relief under the Custody Rule to Sub-Adviser for Not Obtaining Surprise Examination of Custodian Affiliate
  • Incentive Compensation for Financial Institutions: Reproposal

Industry Update

  • Financial Stability Oversight Council Releases Update on Review of Asset Management Products and Activities
  • SEC Chair Mary Jo White Delivers Opening Remarks at the Compliance Outreach Program for Investment Companies and Investment Advisers


  • Second Circuit Rules that Criminal Liability for Violation of Section 206 of the Advisers Act Does Not Require Proof of Intent to Harm
  • SEC Charges Accounting Firm with Conducting Deficient Surprise Exams
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