CCO (Chief Compliance Officer) Content

As previously reported, the Securities and Exchange Commission recently adopted amendments that will require open-end funds to (1) create and transmit summary shareholder reports highlighting key information to investors; and (2) tag the contents of shareholder reports in a structured...

Last week, the SEC adopted a new incentive-based compensation "clawback" rule (the "rule") and related amendments by a 3-2 vote. The final rule could require certain listed registered management investment companies ("funds") to adopt clawback policies as required by their exchanges...

On September 29, 2022, the Financial Crimes Enforcement Network ("FinCEN") issued a final rule regarding beneficial ownership information reporting ("Rule"). FinCEN proposed the Rule in December 2021 to implement Section 6403 of the Corporate Transparency Act ("CTA"), which was...

Earlier this week, the Securities and Exchange Commission adopted amendments that will require open-end funds to (1) create and transmit summary shareholder reports highlighting key information to investors and (2) tag the contents of shareholder reports in a structured data language.

On Wednesday, October 26, 2022, the SEC approved in a 3-2 vote a proposal for a new rule and related amendments to prohibit SEC-registered investment advisers from outsourcing certain services or functions to service providers without meeting minimum requirements. The SEC's stated...

In December 2020, the SEC adopted rule amendments that replaced the existing Investment Advisers Act advertising and cash solicitation rules for investment advisers and private funds with a single, combined "Marketing Rule." The new Marketing Rule does not apply to advertisements...

Earlier this week, ICI submitted supplemental comments (linked below) on the SEC's 2020 disclosure proposal for open-end funds ("funds"). On September 15, the SEC's Office of the Investor Advocate filed with the SEC a research paper on funds' choice of performance benchmarks and...

On September 27, the SEC's Division of Enforcement announced that it had charged fifteen broker-dealers and one investment adviser associated with one of the broker-dealers with "widespread and longstanding failures by the firms and their employees to maintain and preserve electronic...

Earlier this week, the SEC announced its settlement of enforcement actions against 15 broker-dealers and one investment adviser for failing to comply with recordkeeping requirements to maintain and preserve certain "off-channel communications."

Earlier this week the SEC charged investment adviser Toews Corporation (the "adviser") with violations of the Advisers Act and the proxy voting rule thereunder in connection with the adviser's proxy voting-related conduct.