Investment Management Regulatory Update - September 2015
SEC Rules and Regulations
- BEA Releases New Benchmark Survey for Financial Services Providers, Including Managers of Hedge, Private Equity and Other Private Funds and Separate Accounts
- SEC Issues No-Action Relief Clarifying When a Substantive, Pre-existing Relationship Exists
- FinCEN’s Proposed Rule to Require Investment Advisers to Establish AML Programs
- Second Circuit Holds That Whistleblowers Who Report Alleged Wrongdoing Internally Are Entitled to Dodd-Frank’s Anti-Retaliation Protections
Industry Update
- Proposed Treasury Regulations Address Management Fee “Waiver” Arrangements
- Public Statement by Commissioner Luis A. Aguilar on Enhancing the Commission’s Waiver Process
- NFA Proposes Interpretive Notice on Information Systems Security Programs
Litigation
- SEC Charges Citigroup Global Markets for Compliance and Surveillance Failures
- SEC Charges Guggenheim with Failure to Disclose Conflicts of Interest
- SEC Charges Investment Advisory Firm with Fraudulent Fee Retention
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