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SEC Releases Final Interpretation of the Standard of Conduct for Investment Advisers

USA - August 28 2019 The U.S. Securities and Exchange Commission has, for some time, been reviewing the standard of conduct required of investment advisers and...

Brad L. Caswell, Marc E. Elovitz, Brian T. Daly.

OCIE Focusing on Safeguarding of Customer Information and Books and Records Retention

USA - August 28 2019 The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has recently issued risk alerts relating to the safeguarding of customer...

Brad L. Caswell, Marc E. Elovitz, Brian T. Daly.

New Fund-of-Funds Rule for Registered Funds Under SEC Consideration

USA - August 28 2019 The SEC is currently considering a rulemaking proposal (“Proposed Fund-of-Funds Rule”), first proposed in December 2018, designed to streamline and...

Brad L. Caswell, Marc E. Elovitz, Brian T. Daly.

National Futures Association Adopts Interpretive Notices Regarding Internal Controls and Cybersecurity

USA - August 28 2019 Effective April 1, 2019, the National Futures Association (“NFA”) recently adopted two interpretive notices that, respectively, impose additional...

Brad L. Caswell, Marc E. Elovitz, Brian T. Daly.

SEC Staff Publishes Statement on LIBOR Transition

USA - July 18 2019 On July 12, 2019, the staffs of several divisions (“Staff”) within the SEC published a statement (“Statement”) on the transition away from the London...

Marc B. Friess, Douglas I. Koff, Kelly Koscuiszka, Atul Joshi, Paul N. Watterson, Phillip J. Azzollini, Anthony Lombardi.