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ICI Default BG
Memo#
34095

Massachusetts Court Invalidates Fiduciary Conduct Standard Regulations

On March 30, 2022, the Superior Court of the Commonwealth of Massachusetts issued an order (attached) invaliding the Massachusetts regulation, finalized in 2020, that imposes a fiduciary duty on broker-dealers and agents. The court stayed the order for 30 days to give the...
ICI Default BG
Memo#
34044

SEC Proposes to Shorten the Settlement Cycle to T+1

On February 9, the Securities and Exchange Commission proposed rules to shorten the standard settlement cycle for most broker-dealer transactions from two business days after the trade date ("T+2") to one business day after the trade date ("T+1").
ICI Default BG
Memo#
34036

SEC Proposes Private Fund Regulatory Reforms

On February 9, the Securities and Exchange Commission voted to propose new rules and amendments under the Investment Advisers Act of 1940 with respect to private fund advisers. The proposal passed by a vote of three-to-one. The proposal's goals are to improve private fund adviser...
ICI Default BG
Memo#
34034

SEC Proposes Amendments to Schedule 13D/G Reporting Requirements

On February 10, the SEC, by seriatim approval, proposed amendments to its rules governing beneficial ownership reporting on Schedules 13D and 13G ("Proposal"). Comments on the proposal are due the later of: (i) April 11, 2022 (60 days following the publication of the proposing release...
ICI Default BG
Memo#
34016

SEC Proposes Amendments to Form PF

On January 26, the SEC approved proposed amendments to Form PF in an open meeting through a three-to-one vote. Generally, Form PF is filed by investment advisers to private funds to provide confidential information to the SEC and the Financial Stability Oversight Council (FSOC) about...
ICI Default BG
Memo#
33982

ICI Submits Comment Letter on the SEC's Electronic Filing Proposals

In November, the SEC issued two proposals. One would mandate the electronic filing of certain forms that currently must be filed on paper, as well as update certain other forms and processes. The other would require electronic filing through EDGAR of documents that currently may be...