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Asset Management ADVocate

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April 7, 2020

A Negative Sign of the Times: Form N-MFP Can Report Negative Yields

On April 7, 2020, the Securities and Exchange Commission (the "SEC") announced an update to the EDGAR system that would allow negative values to be entered in Item C.17 of Form N-MFP.

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April 7, 2020

SEC Staff Publishes Risk Alerts Regarding Reg BI and Form CRS Inspections and Possible COVID-19 Impact

On April 7, 2020, the Securities and Exchange Commission's Office of Compliance Inspections and Examinations ("OCIE") published two risk alerts intended to provide market participants with advance information regarding (1) upcoming inspections for broker-dealer compliance wi

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April 6, 2020

SEC Grants Mutual Funds Short-Term Borrowing/Lending Relief in Response to COVID-19

On March 23, 2020, the Securities and Exchange Commission ("SEC") issued a relief order (the "Order") granting temporary short-term lending and borrowing flexibility to open-end funds and insurance company separate accounts (each, a "fund") to assist such funds in dealing with market disruptio

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April 6, 2020

SEC Provides No-Action Relief Extending Rule 17a-9 to Non-Money Market Funds

In response to the ongoing COVID-19 pandemic and resulting market liquidity issues impacting regulated investment companies, the Securities and Exchange Commission's Division of Investment Management (the "Division") recently issued a no-action letter (the "No-Action Letter

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April 2, 2020

SEC Staff Provide No-Action Relief Relating to Broker-Dealer Net Capital Requirements

On March 30, 2020, the Securities and Exchange Commission ("SEC") Division of Trading and Markets ("Division") issued a No-Action Letter relating to market practices regarding bank sweep programs requested by the Securities Industry and Financial Marke

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April 2, 2020

Update on SEC’s New Relief for Form ADV and Form PF Filing and Delivery Obligations

On March 25, 2020, the Securities and Exchange Commission ("SEC") published new relief that supersedes its March 13, 2020 order for investment advisers filing and delivery obligations of Form ADV and Form PF.

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March 31, 2020

SEC Provides Additional Regulatory Relief in Wake of COVID-19

On March 26, 2020, the Securities and Exchange Commission ("SEC"), announced two agency actions providing additional relief to market participants in response to the impacts of COVID-19 on the markets.

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March 27, 2020

Navigating Mutual Funds in Rough Markets—Valuation

In our previous post, we reviewed how the financial markets' reaction to the COVID-19 pandemic requires mutual funds to review, and possibly reclassify, the liquidity of their investments.

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March 26, 2020

Navigating Mutual Funds in Rough Markets—Liquidity

During a recent webinar, Steve explained that the market and trading conditions caused by the COVID-19 pandemic might be "reasonably expected to materially affect one or more of [a mutual fund's] inves

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March 25, 2020

The SEC Stays Busy: CAT Relief in Response to COVID-19 Pandemic, CAT Cybersecurity Relief for SROs, and Enforcement Has Its Eye on Insider Trading

The U.S. Securities and Exchange Commission ("SEC") recently provided relief relating to the implementation of the Consolidated Audit Trail ("CAT").

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March 23, 2020

Another Update on Money Market Mutual Fund Liquidity Facility

Another day, another expansion of the Money Market Mutual Fund Liquidity Facility (the "Facility") from the Federal Reserve Bank of Boston ("FRBB"). As before, I've updated my original post to conform to the current program.

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March 23, 2020

Understanding Circuit Breakers, Our New Reality, in the Time of COVID-19

In the midst of the COVID-19 pandemic, the financial markets have experienced significant volatility. During the course of this volatility, exchanges have halted trading multiple times after declines in trading trigged circuit breakers. In addition, trading floors are transitioning to electronic trading in efforts to prevent the transmission of COVID-19 on physical trading floors.

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March 20, 2020

Update on Money Market Mutual Fund Liquidity Facility & Related No-Action Letter

Yesterday I posted a summary of the Federal Reserve Bank of Boston's Money Market Mutual Fund Liquidity Facility (the "Fac

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March 19, 2020

Information on the Prime and Tax Exempt Money Market Fund Liquidity Facility (Updated 3/23)

The Federal Reserve Bank of Boston ("FRBB") has established a new Money Market Mutual Fund Liquidity Facility. (I'm not sure what acronym to use here; "mmm … Fund Liquidity" would work. Let's just call it the "Facility.") The Facility opened on March 23, 2020.

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March 17, 2020

FINRA Issues Notice Regarding Business Continuity Planning During COVID-19 Outbreak

On March 9, 2020, FINRA released Regulatory Notice 20-08 (the "Regulatory Notice") providing guidance and limited relief to its member broker-dealers during the COVID-19 pandemic.