Disclosure Content

Last month, FINRA filed with the SEC proposed amendments to Rule 2210 (Communications with the Public) (the "rule"). If adopted, the amendments would permit a FINRA member to project the performance or provide a targeted return with respect to a security or asset allocation or other...

On December 11, 2023, Investment Company Institute (ICI) submitted comments to the Commodity Futures Trading Commission (CFTC) regarding its proposed amendments to Regulation 4.7 (the "Proposal"). While the Proposal contained several proposed amendments that would affect commodity...

The Office of Information and Regulatory Affairs released the Fall 2023 Unified Agenda of Regulatory and Deregulatory Actions on December 6, 2023. The agenda includes regulatory actions that the Securities and Exchange Commission and Commodity Futures Trading Commission expect to take...

Last week, the Securities and Exchange Commission stayed amendments that will require enhanced disclosure when an issuer repurchases its own equity securities ("Share Repurchase Rule"). The Commission stayed the amendments in light of a decision from the U.S. Court of Appeals for the...

On October 31, 2023, the Department of Labor (DOL) released its long-awaited new regulatory package on fiduciary investment advice. The package includes a proposal to amend the regulation defining who is a "fiduciary" under section 3(21) of ERISA and section 4975(e)(3) of the Internal...

On October 13, the Securities and Exchange Commission adopted new Rule 10c-1a ("Final Rule") under the Securities Exchange Act of 1934 ("Exchange Act"), which is intended to increase transparency and efficiency in the securities lending market. We were pleased that the Final Rule was...

On September 29, 2023, the Securities and Exchange Commission (SEC), by seriatim, issued a proposal (the "Proposal") related to registration of offerings of registered index-linked annuities (RILAs). Specifically, the SEC proposed to amend Form N-4, which is the form currently used by...