ComplianceAlert

Private Fund Exam Findings Released (Video)

Video: “SEC to Private Funds: Prepare for an Exam” On June 23, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert (the “Alert”) discussing observations from its private fund examinations over time. The Alert did not state the time period of the examinations included. However, any private fund manager that…

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ComplianceAlert

SEC Issues New Guidance and Proposed Amendment

The SEC has been busy this past month issuing new information for asset managers. On July 10th, it issued a proposed amendment to Form 13F filings. Then, last week, the SEC issued guidance on proxy voting for investment advisers. The Form 13F change is significant for institutional equity trading advisers. Section 13(f) Proposed Amendment The…

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ComplianceAlert

Private Fund Exam Findings Released

On June 23, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert (the “Alert”) discussing observations from its private fund examinations over time. The Alert did not state the time period of the examinations included. However, any private fund manager that has been examined within the past two years should…

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ComplianceAlert

LIBOR Transition Exams Imminent

On June 18, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert (the “Alert”) outlining its plans to examine registrants’ readiness for the London Interbank Offered Rate (LIBOR) benchmark transition. The reference rate for loans, interest rate swaps, derivatives, and bonds is due to expire by 2022, and firms are…

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ComplianceAlert

SEC No-Action Relief for Funds/BDCs

The SEC’s Division of Investment Management (“IM”) has been busy issuing and updating guidance for investment companies and business development companies (“BDCs”) in light of recent market events related to the COVID-19 outbreak. Two significant letters were released in late May. The first, an SEC No-Action letter to the Investment Company Institute (“ICI”) and SIFMA…

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