Investment Management Regulatory Update - September 2015
Client Newsletter

Created date


SEC Rules and Regulations

  • BEA Releases New Benchmark Survey for Financial Services Providers, Including Managers of Hedge, Private Equity and Other Private Funds and Separate Accounts
  • SEC Issues No-Action Relief Clarifying When a Substantive, Pre-existing Relationship Exists
  • FinCEN’s Proposed Rule to Require Investment Advisers to Establish AML Programs
  • Second Circuit Holds That Whistleblowers Who Report Alleged Wrongdoing Internally Are Entitled to Dodd-Frank’s Anti-Retaliation Protections

Industry Update

  • Proposed Treasury Regulations Address Management Fee “Waiver” Arrangements
  • Public Statement by Commissioner Luis A. Aguilar on Enhancing the Commission’s Waiver Process
  • NFA Proposes Interpretive Notice on Information Systems Security Programs


  • SEC Charges Citigroup Global Markets for Compliance and Surveillance Failures
  • SEC Charges Guggenheim with Failure to Disclose Conflicts of Interest
  • SEC Charges Investment Advisory Firm with Fraudulent Fee Retention