Client Alert

Investment Management Legal and Regulatory Update - April 2020

Latest developments

• SEC Extends Time Periods of Regulatory Relief for Funds and Advisers Impacted by Coronavirus
  • Relief for Registered Investment Companies
  • Relief for Investment Advisers and Exempt Reporting Advisers
• SEC Staff Grants Temporary Liquidity Relief to Mutual Funds
• OCIE Publishes Observations on Cybersecurity and Resiliency Practices

1. Governance and Risk Management
2. Access Rights and Controls
3. Data Loss Prevention
4. Mobile Security
5. Incident Response and Resiliency
6. Vendor Management
7. Training and Awareness

• SEC Requests Comment on Fund Names Rule
• SEC Staff Issues Updated FAQs on Form CRS and Regulation Best Interest

Litigation/Enforcement Actions

• Adviser charged by the SEC with Failing to Maintain Adequate Controls for Material Nonpublic Information

Compliance Dates for final rules

• Investment Company Reporting Modernization: New Form N PORT (As Amended)
• Rescission of Form N-Q
• Form N-1A
• FAST Act Amendments Impacting Registration Statement and N-CSR Filings
• Form CRS, Client Relationship Summary