On January 25th, the Second Circuit affirmed the dismissal of complaints alleging that mutual fund companies and their related entities violated the disclosure requirements of the Securities Act by failing to disclose certain alleged conflicts of interest. The Second Circuit held that the Securities Act does not require mutual funds to make disclosures that are not otherwise called for by the securities laws. Form N-1A, which investment companies use to register their mutual fund shares, calls for the disclosure only of those risks specific to that fund. The Court noted that the SEC, in its amicus submission, took the view that the risks identified by plaintiffs were not unique; the potential that a company's stock price is inflated by biased research coverage exists throughout the market. In re Morgan Stanley Info. Fund Sec. Litig.