February 24, 2020

Blackstone Receives Order on Novel Exemptive Application under the 1940 Act

On February 19, 2020, the SEC issued an order granting an application for exemptive relief filed by Blackstone Alternative Investment Funds (Blackstone Trust) and Blackstone Alternative Investment Advisors LLC. The exemptive relief permits the Blackstone Trust’s board of trustees to approve new sub-advisory agreements and material amendments to existing sub-advisory…

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January 24, 2020

Blackstone Receives Notice on Novel Exemptive Application under the 1940 Act

On January 21, 2020, the SEC issued a “notice” relating to an exemptive application filed by Blackstone Alternative Investment Funds (Blackstone Trust) and Blackstone Alternative Investment Advisors LLC (Blackstone). The application requests relief that would permit the Blackstone Trust’s board of trustees to approve new sub-advisory agreements and material amendments…

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January 16, 2020

SEC Proposes to Modernize Auditor Independence Rules

On December 30, 2019, the SEC proposed amendments to codify certain staff consultations and modernize certain aspects of its auditor independence regulatory framework (Proposed Amendments). The Proposed Amendments are intended to eliminate non-substantive rule breaches and unnecessary reviews by audit committees of non-substantive matters (i.e., relationships and services that would…

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November 18, 2019

SEC’s Office of Compliance Inspections and Examinations Issues Risk Alert to Provide Observations from Examinations of Investment Companies and Observations from Money Market Fund and Target Date Fund Examination Initiatives

On November 7, 2019, the staff of the SEC’s Office of Compliance Inspections and Examinations (staff) issued a risk alert (Risk Alert) on the most frequently cited deficiencies and weaknesses that the staff has observed in recent examinations of registered investment companies. The Risk Alert also provides staff observations from national examination initiatives relating to money market funds and target date funds.

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November 8, 2019

SEC Proposes Updates to Filing Fee Disclosure and Payment Methods

On October 24, 2019, the SEC issued a release proposing amendments to various rules and forms under the 1933 Act, 1934 Act and 1940 Act (Release) applicable to investment companies registered under the 1940 Act (funds). The amendments would, among other things, require filing fee disclosures under Forms N-2, N-5…

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October 24, 2019

Compliance and Effective Dates Set for New Exchange-Traded Funds Rule

On October 24, 2019, the SEC’s adopting release (Release) for Rule 6c-11 (Rule) under the Investment Company Act of 1940, as amended (1940 Act), to modernize the regulatory framework for most exchange-traded funds (ETFs) was published in the Federal Register, which means that the various compliance and effective dates for…

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October 23, 2019

SEC Staff Issues Frequently Asked Questions Regarding Disclosure of Certain Financial Conflicts Related to Investment Adviser Compensation

On October 18, 2019, the SEC staff issued frequently asked questions (FAQ) about required disclosures of conflicts related to compensation advisers receive, such as 12b-1 fees and revenue sharing, for recommending certain investment products. In the FAQ, the staff of the Division of Investment Management discusses…

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October 23, 2019

SEC Proposes Amendments to Exemptive Applications Procedures

On October 18, 2019, the SEC proposed rule amendments to establish an expedited review procedure for exemptive applications under the Investment Company Act of 1940 that are substantially identical to recent precedent, as well as a new informal internal procedure for applications that would not qualify for the new expedited…

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October 8, 2019

Division of Investment Management Issues ADI on Performance and Fee Issues

On October 2, 2019, the Disclosure Review and Accounting Office (“DRAO”) of the SEC’s Division of Investment Management (the “Division”) issued Accounting and Disclosure Information (“ADI”) 2019-09 on “Performance and Fee Issues.” The ADI provides the DRAO staff’s observations from reviewing fund disclosure filings with the…

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October 1, 2019

SEC Adopts New Rule for Exchange-Traded Funds

On September 25, 2019, the SEC adopted Rule 6c-11 (Rule) under the Investment Company Act of 1940, as amended (1940 Act), to modernize the regulatory framework for most exchange-traded funds (ETFs).  The Rule eliminates the need for ETFs that can operate under its conditions to obtain an exemptive order from…

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