Temporary changes to document retention requirements The U.S. Securities and Exchange Commission recently issued a statement temporarily amending certain documentation requirements under Rule 302(b) of Regulation S-T. The changes come in response to the logistical challenges posed by COVID-19. Rule 302(b) requires that signatories of documents electronically filed with the [...]
Are your documents and website up to ADA standards? The Americans with Disabilities Act of 1990 (ADA) lays out guidelines for how to make documents widely accessible and can be applied to certain file types often used for fund documents. Many funds are voluntarily making the transition to independently adopt [...]
New Proposed Rule to Affect EDGAR Filing System WHAT HAPPENED? On Aug. 21, 2020, the United States Securities and Exchange Commission proposed a new rule under Regulation S-T, Rule 15, which aims to make the EDGAR filing process more efficient, consistent, and reliable. The Rule would alter the process [...]
Open-End Funds: Proposed Amendments to Reporting and Disclosure Requirements WHAT HAPPENED? On Aug. 5, 2020, the United States Securities and Exchange Commission proposed a new set of amendments to mutual fund and exchange-traded fund disclosure requirements. The package includes, among other things, changes to visual presentation requirements and the [...]
SEC Adopts Rule Amendments, Issues Guidance on Proxy Voting Process WHAT HAPPENED? On July 22, 2020, the United States Securities and Exchange Commission adopted rule amendments and issued additional guidance on the proxy voting responsibilities of investment advisers and third-party proxy voting advice service providers. The goal of the [...]
SEC Proposes Changes to Form 13F WHAT HAPPENED? On July 10, 2020, the United States Securities and Exchange Commission proposed amendments to Form 13F reporting. The changes would affect the filing threshold for institutional advisers and several other requirements. Because the filing requirements have not been updated since adoption of [...]
New Final Rule: SEC to Modernize Closed-End Fund Requirements WHAT HAPPENED? On April 8, 2020, the United States Securities and Exchange Commission adopted a new final rule which will modernize business development company (BDC) and closed-end fund (CEF) requirements to meet those already applied to operating companies. The new [...]
New Final Rule: Summary Prospectus for Variable Annuities WHAT HAPPENED? Recently, the Securities and Exchange Commission adopted a new final rule, 498A, and form amendments which intend to modernize disclosure requirements and allow investors to make more informed decisions about variable annuity and variable life insurance contracts. The new [...]
The SEC Issues Regulatory Relief Amid Form ID and Notarization Challenges WHAT HAPPENED? On March 23, 2020, the SEC acknowledged in an announcement that it is aware of challenges with meeting certain requirements for initial access to the EDGAR filing system; in particular, the Form ID application process and [...]
SEC Issues Additional Relief and Guidance as COVID-19 Creates Obstacles WHAT HAPPENED? In response to the unusual state of global securities infrastructures stemming from COVID-19, the SEC is continuing to provide regulatory relief to struggling entities. This week, the SEC expanded on a recently released relief package to extend [...]
