Ropes & Gray Discusses FinCEN Proposal to Extend Anti-Money Laundering Requirements

By Ama A. Adams, Brendan C. Hanifin and Kurt Fowler March 29, 2024 by renholding

On February 13, the Financial Crimes Enforcement Network (“FinCEN”), within the U.S. Treasury Department, issued a Notice of Proposed Rulemaking (“Proposed Rule”) that would extend certain anti-money laundering program requirements to:

investment advisers registered (“RIAs”) with the Securities and Exchange

…

Kirkland & Ellis Discusses FinCEN Proposal to Increase Anti-Money Laundering Requirements for Investment Advisers

By Norm Champ P.C. Scott A. Moehrke, P.C. Josh Westerholm, P.C. and Nick Niles February 27, 2024 by renholding

On February 13, the U.S. Treasury, Financial Crimes Enforcement Network (“FinCEN”) proposed¹ (the “Proposed Rule”) to apply affirmative anti-money laundering and countering-the-financing-of-terrorism (“AML/CFT”) program obligations as prescribed by the Bank Secrecy Act (the “BSA…

SEC Proposal on Predictive Data Analytics Lacks Statutory Authorization

By Andrew Vollmer December 7, 2023 by renholding

In August, the SEC proposed rules requiring broker-dealers (BDs) and investment advisers (IAs) to identify and eliminate or neutralize the effect of conflicts of interest associated with their use of technologies, widely defined (Proposal). My primary concern about the Proposal …

Skadden Discusses Proposed SEC Expansion of Custody Rule Safeguards for Investment Advisers

By Anna Rips, Anastasia T. Rockas, TJ Wells and Marc Sana April 4, 2023 by renholding

On February 15, 2023, the Securities and Exchange Commission (SEC) proposed new rules and amendments (Proposal) to Rule 206(4)-2 (Custody Rule) under the Investment Advisers Act of 1940 (Advisers Act). The Proposal would, if adopted as written:

Redesignate the current

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SEC Chair Gensler Speaks Before the Investor Advisory Committee

By Gary Gensler March 3, 2023 by renholding

Good morning. I am pleased to join the Investor Advisory Committee. As is customary, I’d like to note that my views are my own and I am not speaking on behalf of the Commission or SEC staff.

I want to

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SEC Chair Gensler on Proposed Rules About Investment Adviser Custody

By Gary Gensler February 17, 2023 by renholding

Today [February 15], the Commission is considering a proposal to expand and enhance the role of qualified custodians when registered investment advisers custody assets on behalf of their investors. I support this proposal because, in using important authorities Congress granted …

Davis Polk Discusses SEC’s Final Rules on Proxy Advisory Firms

By Ning Chiu, Nicole Brookshire, Joseph A. Hall, Michael Kaplan and Richard D. Truesdell Jr. July 21, 2022 by renholding

When the SEC adopted the rules governing proxy advisory firms two years ago, then-Chair Clayton emphasized that the rules were “the fruits of a rigorous and well-functioning rulemaking process where final rules reflect and benefit from the input of a …

SEC Commissioner Peirce on ESG Disclosures Proposal

By Hester M. Peirce May 27, 2022 by renholding

Thank you, Mr. Chair. A key impetus for today’s [May 25’s] rulemaking[1] is a legitimate concern about the practice of greenwashing by investment advisers and investment companies. This concern is real because advisers can mint money by calling their

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SEC Investment Management Chief Speaks on Doing Investment Companies Well

By William A. Birdthistle March 30, 2022 by renholding

Good morning. Thank you, Eric, for your kind introduction. I appreciate the ICI’s invitation and I hope – if you decide ever to renew it – that I’ll be able to join you all in person someday.

Please allow me,

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Sullivan & Cromwell Discusses SEC’s Proposed New Cybersecurity Risk-Management Rules for Investment Advisers and Firms

By Whitney Chatterjee, Donald Crawshaw, Eric Diamond, William Farrar and Anthony Lewis March 24, 2022 by renholding

On February 9, 2022, the Securities and Exchange Commission (the “SEC”) voted 3 to 1 (Commissioner Peirce dissenting[1]) to propose cybersecurity risk management rules and amendments for registered investment advisers, registered investment companies and business development companies (the …

SEC Chairman Gensler Speaks Before the Investor Advisory Committee

By Gary Gensler March 11, 2022 by renholding

It’s good to be back with the Investor Advisory Committee (IAC) again. As is customary, I’d like to note that my views are my own, and I’m not speaking on behalf of the Commission or SEC staff.

I’d like to

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Davis Polk Offers Update on SEC’s New Investment-Management Rules and Lawsuits

By Leor Landa, Gregory S. Rowland, Michael S. Hong, Sarah E. Kim and Marc J. Tobak March 8, 2022 by renholding

Rules and regulations

SEC proposes expanded cyber oversight after Gensler signals more on the way

The Securities and Exchange Commission (SEC) proposed new cybersecurity rules for investment advisers and investment companies that would require policies and procedures, annual reviews, reporting …

SEC Investment-Management Chief Speaks at Investment-Adviser Conference

By William A. Birdthistle March 4, 2022 by renholding

Good morning. Thank you, Karen, for your kind introduction and for inviting me to speak today. I am delighted to join you for my first public address as the Director of the Division of Investment Management.

Let me begin, if

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SEC Commissioner Peirce Speaks on Private Fund Advisers Proposal

By Hester M. Peirce February 11, 2022 by renholding

Today’s [February 9] proposal represents a sea change. It embodies a belief that many sophisticated institutions and high net worth individuals are not competent or assertive enough to obtain and analyze the information they need to make good investment decisions

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SEC Commissioner Crenshaw Speaks on Private Fund Advisers Proposal

By Caroline A. Crenshaw February 11, 2022 by renholding

Investment advisers are their clients’ fiduciaries. This means that investment advisers are legally obligated to serve their client’s best interest.[1] This standard of conduct is not an aspirational goal. It must be meaningful and offer the real protections investors

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Davis Polk Discusses U.S. Strategy on Countering Corruption Report

By Daniel S. Kahn, Greg D. Andres, Martine M. Beamon, Angela T. Burgess and Patrick S. Sinclair December 21, 2021 by renholding

On June 3, 2021, President Biden issued the Memorandum on Establishing the Fight Against Corruption as a Core United States National Security Interest (the Anti-Corruption Memo). The Anti-Corruption Memo directed senior figures from the administration’s national security team to oversee …

Davis Polk Discusses SEC Request for Information on Digital Engagement by Broker-Dealers, Investment Advisers

By Gabriel D. Rosenberg, Jai R. Massari, Tyler X. Senackerib, Margaret E. Tahyar and Zachary J. Zweihorn September 24, 2021 by renholding

In light of the growing popularity of digital investing platforms and increased scrutiny of these platforms by Congress, the SEC has released a broad request for information and public comment (RFI) on all matters related to the use of digital …

SEC Chair Speaks at Meeting of Investor Advisory Committee

By Gary Gensler June 14, 2021 by renholding

Good morning. Thank you Jennifer, Heidi, and all the committee members for having me. I enjoyed meeting with members of the Executive Committee yesterday and am thrilled to meet the whole committee for the first time. I’m grateful for the

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SEC Commissioner Lee on Protecting, Serving, and Empowering Investors

By Allison Herren Lee March 9, 2020 by renholding

Thank you Karen [Barr] and thank you all for hosting me today [March 5]. I appreciate IAA’s engagement on the issues important to its members and to the broader markets, and I’m honored to have the opportunity to speak to

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SEC Chairman Talks Main Street Investors, Foreign Corruption, and Market Issues

By Jay Clayton September 11, 2019 by renholding

Thank you for having me and thanks to those who have contributed to today’s [September 9] event—in particular, the Economic Club, Chair, Marie-Josée [Kravis], President, Barbara [Van Allen], as well as panelists Bob [Pisani] and Harold [Ford].

I am grateful

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