On December 8, 2017, citing the “importance of sound data security practices and protocols for sensitive, nonpublic information,” the Securities and Exchange Commission (SEC) adopted a temporary final rule postponing the filing of Form N-PORT on EDGAR until April 30,
IM Insights
Providing securities and derivatives regulatory updates for investment management industry participants
IM Insights, published by Morrison & Foerster LLP, focuses on regulatory and compliance issues affecting financial services and investment management sectors. The blog covers topics such as SEC regulations, FINRA guidance, fund of funds rules, valuation practices for registered investment companies, and implementation of regulations like Regulation Best Interest and Form CRS. It provides updates on enforcement trends, compliance best practices, and legal developments relevant to broker-dealers, investment advisers, and fund managers. The content aims to assist industry participants in navigating complex regulatory frameworks and addressing operational risks associated with securities laws and investment company regulations.
Latest from IM Insights - Page 7
FINRA Issues Report on Its Examination Findings
In December 2017, FINRA issued a report highlighting several key findings from its recent examinations of broker-dealer members. The report is available here.
The report focuses on several observations from recent examinations that FINRA believed would be worth highlighting…
2017 IIA Compliance Workshop – Denver
Thursday, November 30, 2017
9:15 a.m. – 2:00 p.m. MST
Investment Advisor Association Seminar
Westin Denver Downtown
672 Lawrence Street
Denver, CO 80202
The IAA Compliance Workshops are an excellent opportunity to gain practical insights into challenging legal and regulatory…
Open-End Fund Converts to Closed-End Fund
In what has been reported as a market first, the independent directors and shareholders of an open-end fund (mutual fund) agreed to convert an approximately $1 billion open-end fund to an exchange-listed, closed-end fund.
While open-end funds issue shares continuously,…
ThinkingCapMarkets Podcast: Bad Actor Disqualification Provisions
There are very similar disqualification provisions in Regulation A, Regulation CF (Crowdfunding) and Regulation D. These rules make these exemptions from registration unavailable for an offering if the issuer or certain “covered persons” is or has been subject to a…
Treasury Urges Principles-Based Regulation of Money Managers
The U.S. Department of the Treasury’s report on asset management and insurance recommends, among other things, a delay in implementation of the SEC’s liquidity risk management rule and the Department of Labor’s fiduciary rule.
The October 2017 report is the…
SEC Staff Solves Section 28(e)-MiFID II Compliance Conundrum—For Now
In a series of three “no-action” letters, the staff of the Securities and Exchange Commission (SEC) published guidance to address concerns by U.S. broker-dealers and investment advisers about how to comply with Markets in Financial Instruments Directive (MiFID II) rules…
ThinkingCapMarkets Podcast – Replacing Familiar Benchmarks: Preparations to Phase Out the IBORs
Long a mainstay of the financial world, the floating “IBOR” rates, based on the rates of actual or purported interbank offered loans, are now being swept slowly into the dustbin of history. The quantity, in both number and size, of…
ThinkingCapMarkets Podcast: FINRA Communication Rules
All communications by FINRA member firms are subject to the communications rule, which has approval and review, recordkeeping, filing and content standards. The rule also includes exceptions from many of its requirements. FINRA recently updated its advice relating to the…
Mutual Fund Liquidity Risk Management
Wednesday, October 18, 2017
Voltaire Advisors Breakfast Briefing
The New York Athletic Club
180 Central Park South
New York, NY 10019
Partner Jay Baris will participate in a panel discussion entitled “Operational & implementation Challenges for Funds & Advisers.” The…