Sullivan & Cromwell Discusses SEC Proposal to Enhance Proxy Voting Disclosure by Investment Funds

On September 29, 2021, the SEC issued a proposed rulemaking to enhance the information mutual funds, exchange-traded funds and other registered management investment companies (“funds”) report annually about their proxy votes.  The proposal also would require so-called “institutional investment managers” subject to section 13(f) of the Exchange Act (“managers”), which includes a broad range of investors in U.S. publicly traded equities, including some who are not “managers” in the conventional sense, to report annually regarding their voting of proxies related to executive compensation “say-on-pay” matters.  The proposed rulemaking—the first to be issued under the leadership of SEC Chairman Gary Gensler—touches … Read more

Sullivan & Cromwell discusses Money Market Fund Reform

On July 23, 2014, the Securities and Exchange Commission voted 3-2 to adopt amendments to the rules that govern money market funds under the Investment Company Act of 1940. The amendments include the following:

  • Floating Net Asset Value Requirement: Institutional, non-government money market funds will no longer be permitted to maintain a stable net asset value per share, and instead must sell and redeem shares based on the current market value of the securities in their underlying portfolios, rounded to the nearest 1/100th of one percent (e.g., $1.0000). Government and retail money market funds would be permitted to continue

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Sullivan & Cromwell discusses Proposed Regulation of Private Equity Investment in Insurers

SUMMARY

Citing a trend in recent years of private equity firms acquiring insurers, particularly life insurers writing fixed and indexed annuity contracts, the New York State Department of Financial Services on May 14, 2014 released for public comment proposed amendments to its regulations governing the approval process for the direct or indirect acquisition of control of insurance companies domiciled in New York. The proposed amendments seek to reduce “the possibility that any person seeking to acquire control of a New York domestic insurer has interests that conflict with the interests of policyholders, shareholders or the public” and “minimiz[e] the potential … Read more