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SEC proposes offering reforms for business development companies and registered closed-end funds

USA - March 21 2019 On Wednesday, March 20, the Securities and Exchange Commission voted to propose rule amendments to implement certain provisions of the Small Business...

Cynthia R. Beyea, Payam Siadatpour, Terri G. Jordan, Vlad M. Bulkin, Stephani M. Hildebrandt, R. Christian Walker, Steven B. Boehm.


And now for some good newsSEC no-action position provides limited relief for fund in-person voting requirements

USA - March 14 2019 On February 28, 2019, the Chief Counsel’s Office of the Securities and Exchange Commission’s Division of Investment Management issued a...

Cynthia R. Beyea, Payam Siadatpour, Ronald D. Coenen, Jr., Terri G. Jordan, Vlad M. Bulkin, Stephani M. Hildebrandt, Stephen E. Roth, Adam W. Park, R. Christian Walker, Steven B. Boehm.


SEC proposes to expand “testing-the-waters” provisions to all issuers

USA - February 25 2019 On February 19, 2019, the Securities and Exchange Commission (SEC) announced a proposal to expand the “testing-the-waters” exemption to all issuers...

Cynthia R. Beyea, Payam Siadatpour, Terri G. Jordan, Vlad M. Bulkin, Stephani M. Hildebrandt, R. Christian Walker, Dwaune L. Dupree, Steven B. Boehm.


Fund of funds flexibility - What’s important to BDCs and closed-end funds in the SEC’s rule proposal, including a request for comments on AFFE

USA - January 14 2019 On December 19, 2018, the US Securities and Exchange Commission (SEC) issued a release (the Release) proposing new rule 12d1-4 (the Proposed Rule) and...

Cynthia R. Beyea, Payam Siadatpour, Ronald D. Coenen, Jr., Terri G. Jordan, Vlad M. Bulkin, Stephani M. Hildebrandt, Patricia C. Buxton, Frederick R. Bellamy, Steven B. Boehm.


The New York State Department of Financial Services issues guidance on corporate whistleblowing programs

USA - January 14 2019 On January 7, 2019, the New York State Department of Financial Services (DFS or the "Department") issued guidance regarding internal whistleblowing...

Meghana D. Shah, Kara D. Ford, John S. Pruitt.