This post continues our assessment of whether the Limited Derivatives User requirements of Rule 18f-4(c)(4) effectively and efficiently accomplish the SEC’s aim of providing “an objective standard to identify funds that use derivatives in a limited manner.” Here
Continue Reading Assessing the Limited Derivatives User Requirements of Rule 18f-4—Notional Amounts
Perkins Coie LLP Blogs
Latest from Perkins Coie LLP
Strict Liability for Debt Collectors Attempting to Collect a Time-Barred Debt Through Litigation
In 2020, the Consumer Financial Protection Bureau (CFPB) promulgated 12 C.F.R. § 1006.26, amending Regulation F, to implement and interpret the Fair Debt Collection Practices Act (FDCPA). It will become effective on November 30, 2021. Section 1006.26 prohibits debt collectors
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RIAs and Bitcoin Futures ETFs: Forget Not Thy CPO and CTA Analysis
The financial press is awash this morning with reports that the launch of a bitcoin futures exchange-traded fund (a “BTC Futures ETF”) may be imminent.
Before recommending that clients invest directly in bitcoin or in a BTC Futures ETF, a
Continue Reading RIAs and Bitcoin Futures ETFs: Forget Not Thy CPO and CTA Analysis
A New Guide: “Handling the Tricky Aspects of Director Departures”
Stewart Landefeld has put his deep knowledge – of many decades – to use in putting together this excellent “Handling the Tricky Aspects of Director Departures” Guide. Check it out!
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OSHA Vaccination ETS Moving Forward
The Labor Department’s Occupational Safety and Health Administration (OSHA) has taken steps to move forward with President Biden’s plan to require private-sector workers to be vaccinated against COVID-19 or be regularly tested. OSHA submitted the initial text of the proposed
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Assessing the Limited Derivatives User Requirements of Rule 18f-4—Notional Amounts
This post continues our assessment of whether the Limited Derivative User requirements of Rule 18f-4(c)(4) effectively and efficiently accomplish the SEC’s aim of providing “an objective standard to identify funds that use derivatives in a limited manner.” Here
Continue Reading Assessing the Limited Derivatives User Requirements of Rule 18f-4—Notional Amounts
Upcoming Webcast: “Anatomy of a Proxy – Practice Tips from the Experts”
We have partnered with DFin to bring you a complimentary webcast – “Anatomy of a Proxy: Practice Tips from the Experts” – to be held on Wednesday, November 3rd from 2:00-3:00 pm eastern. Please register to catch this
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Assessing the Limited Derivatives User Requirements of Rule 18f-4—Costs
Our last series of posts on Rule 18f-4 have struggled to understand how its Limited Derivatives User requirements are supposed to work. We have done the best we could to explain the process for calculating a fund’s derivatives exposure,
Continue Reading Assessing the Limited Derivatives User Requirements of Rule 18f-4—Costs
Preparing for DOJ’s White Collar Enforcement “Surge”: Five Compliance Practices for Companies to Shore Up Now
During a speech last week to a group of white collar defense attorneys, John Carlin, a senior official at the Department of Justice (DOJ) confirmed what many in the white collar and corporate compliance space have been preparing for since
Continue Reading Preparing for DOJ’s White Collar Enforcement “Surge”: Five Compliance Practices for Companies to Shore Up Now
FTC Follows Through on Prioritizing Investigations into False Advertising in Healthcare Markets
Key Takeaways:
- The FTC is prioritizing investigations into and actions against false and misleading advertisements in healthcare markets.
- Companies with healthcare products, especially those advertising medical treatments, should take care to ensure they do not overstate the efficacy of those