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FinCEN requires financial institutions to obtain beneficial ownership information

USA - June 1 2016 FinCEN’s new CIP beneficial owner rules may hinder the ability of shell and nominee companies to directly access the US financial system without...

Amy Natterson Kroll, Christopher D. Menconi, Joshua B. Sterling, Monica L. Parry, W. John McGuire.

SEC Chair discusses enhanced director oversight

USA - April 7 2016 In remarks at the Mutual Fund Directors Forum 2016 Policy Conference on March 29, US Securities and Exchange Commission (SEC) Chair Mary Jo White...

Christopher D. Menconi, Roger P. Joseph, Lea Anne Copenhefer, Philip K.W. Smith.

Understanding the SEC’s proposal on registered funds’ use of derivatives and financial commitment transactions

USA - March 23 2016 On December 11, 2015, the US Securities and Exchange Commission (SEC) voted 3-1 in favor of proposing a new ruleRule 18f-4 (Proposed Rule) under the...

Daniel N. Budofsky, Akshay N. Belani, Thomas V. D'Ambrosio, Laura E. Flores, Sean Graber.

SEC exam staff shares observations on outsourced chief compliance officers

USA - November 19 2015 On November 9, the US Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections, and Examinations (OCIE) released a Risk Alert...

Barry N. Hurwitz, Roger P. Joseph, John J. O’Brien, Monica L. Parry, W. John McGuire.

SEC clarifies BDC transactions with certain second-tier affiliates

USA - December 19 2014 The SEC's Division of Investment Management has clarified which restrictions apply to BDC's co-investment transactions with limited partners of a...

Barry N. Hurwitz.