On January 12, 2017, the SEC's Office of Compliance Inspections and Examinations ("OCIE") released its 2017 Examination Priorities. In addition to the areas of focus provided below, OCIE expects to allocate resources to the examination of private fund ...

Seward & Kissel LLP


40 Act Blog - 5 new articles


OCIE Releases its 2017 Examination Priorities

On January 12, 2017, the SEC's Office of Compliance Inspections and Examinations ("OCIE") released its 2017 Examination Priorities.  In addition to...

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OCIE Multi-Branch Adviser Initiative Risk Alert

The SEC's Office of Compliance Inspections and Examinations ("OCIE") has issued a Risk Alert regarding the launch of its Multi-Branch Adviser...

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Division of Investment Management Provides Interpretive Guidance on Section 22(d) Restrictions

In an interpretive letter dated January 11, 2017 (the “Staff Letter”), the Office of Chief Counsel of the Division of Investment Management...

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SEC Issues No-Action Relief in Connection with the Reallocation of a Unitary Fee without Shareholder Approval

In a recent no-action letter, the staff of the Division of Investment Management (the “Staff”) indicated that it would not recommend enforcement...

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SEC No-Action Position on use of Affiliated Person as Broker to execute FX Transactions

In a recent no-action letter, the SEC provided assurances that it would not recommend enforcement action under Section 17(e) of the 1940 Act if...

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