Sullivan & Cromwell discusses Exchange-Traded Products: SEC Requests Comments on Topics Related to the Listing and Trading of Exchange-Traded Products on National Securities Exchanges and Sales of Such Products by Broker-Dealers

The Securities and Exchange Commission recently published a request for comment on topics relating to its oversight of exchange-traded products under the Securities Exchange Act of 1934, and particularly the listing and trading of exchange-traded products on national securities exchanges and the sales of such products by broker-dealers.

In the request for comment, the SEC states that it is soliciting public comment to help inform its review of the listing and trading of new, novel or complex exchange-traded products, including requests for exemptive and no-action relief under the Exchange Act and filings by exchanges to adopt listing standards applicable to … 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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