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SEC Staff Issues No-Action Letter Extending Existing Multi-Manager Exemptive Relief to Non-Wholly-Owned Affiliated Sub-Advisers

USA - August 9 2019 On July 9, 2019, the staff of the SEC's Division of Investment Management issued a no-action letter to the BNY Mellon family of funds and BNY Mellon...

Nathaniel Segal, Jacob C. Tiedt.

Court Finds for Defendant Investment Adviser in Section 36(b) Excessive-Fee Case

USA - August 9 2019 On August 5, 2019, the U.S. District Court for the Central District of California found for the defendant, Metropolitan West Asset Management, LLC...

Nathaniel Segal, Jacob C. Tiedt.

OCIE Issues Risk Alert Relating to Investment Adviser Oversight of Supervised Persons with Disciplinary Histories

USA - August 9 2019 On July 23, 2019, the SEC's Office of Compliance Inspections and Examinations (OCIE) issued a risk alert outlining its observations and...

Nathaniel Segal, Jacob C. Tiedt.

FINRA Issues Supplemental Guidance on Giving Credit for Extraordinary Cooperation

USA - August 9 2019 On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which...

Nathaniel Segal, Jacob C. Tiedt.

Second Circuit Creates Split Regarding Private Right of Action for Rescission under Section 47(b) of the 1940 Act

USA - August 9 2019 On August 5, 2019, the U.S. Court of Appeals for the Second Circuit created a split with other courts regarding whether there is a private right of...

Nathaniel Segal, Jacob C. Tiedt.