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Article
Publication date: 2 May 2017

Stephen Cohen, Megan Johnson, Gary Brooks and Brooke Higgs

To explain the new rules, forms, and amendments to current rules and forms (Final Rule) that the Securities and Exchange Commission (SEC) has adopted to modernize the reporting of…

Abstract

Purpose

To explain the new rules, forms, and amendments to current rules and forms (Final Rule) that the Securities and Exchange Commission (SEC) has adopted to modernize the reporting of information provided by registered investment companies (funds) and to improve the quality and type of information that funds provide to the SEC and investors.

Design/methodology/approach

Discusses the background leading up to the Final Rule, provides an overview and summary of the Final Rule’s key components, and highlights issues that may be raised by the new reporting regime.

Findings

The Final Rule will have a significant effect on many funds. Funds will experience a substantially increased reporting burden with respect to both the frequency of reporting and the granularity of information required.

Practical implications

Fund managers and fund service providers should begin to evaluate the impact of the Final Rule, the processes that will need to be implemented to prepare filings on new forms, and the changes in fund disclosure practices that will be required in response to the amendments to certain forms.

Originality/value

Practical guidance from financial services lawyers specializing in the investment management industry.

Details

Journal of Investment Compliance, vol. 18 no. 1
Type: Research Article
ISSN: 1528-5812

Keywords

Article
Publication date: 2 November 2015

Nathan J. Greene

To explain proposed rules recently issued by the US Securities and Exchange Commission (SEC) that would dramatically expand both public and non-public reporting of portfolios and…

Abstract

Purpose

To explain proposed rules recently issued by the US Securities and Exchange Commission (SEC) that would dramatically expand both public and non-public reporting of portfolios and other data by US registered investment companies. A companion article covers new reports proposed at the same time for investment advisers that file Form ADV with the SEC.

Design/methodology/approach

Explains how the proposed rules intend to rescind Form N-Q and adopt a new portfolio holding form, Form N-PORT, which would require expansive monthly portfolio and risk reporting; describes amendments to Regulation S-X which would both enhance and standardize derivatives disclosures in fund financial statements; and details the reporting requirements for a new annual ‘census-style’ reporting form, Form N-CEN, which would replace an obsolete existing SEC form, Form N-SAR.

Findings

While it still remains to be seen how the final rules will be written, it is clear that US registered investment companies will be subject to broader reporting requirements. Investment companies are likely to incur increased costs due to the detailed nature of the information being requested and the frequency with which they will be required to file. Access to additional and enhanced information will have consequences for investment companies with respect to SEC examinations and enforcement activity.

Practical implications

Senior management and boards of investment companies should understand the basic framework of the proposed requirements. An operations and finance working group may need to be established by companies in order to coordinate the planning and preparation process for the requirements. Firms also should determine whether their service providers have the necessary resources to assist in complying with the proposed filing requirements.

Originality/value

Practical guidance from experienced investment funds lawyer.

Details

Journal of Investment Compliance, vol. 16 no. 4
Type: Research Article
ISSN: 1528-5812

Keywords

Article
Publication date: 3 May 2016

Ryan P. Brizek, P. Georgia Bullitt, Rose F. DiMartino, Margery K. Neale and P. Jay Spinola

To describe and analyze a proposed rule recently issued by the US Securities and Exchange Commission (“SEC”) that would overhaul the use of derivatives and financial commitment…

Abstract

Purpose

To describe and analyze a proposed rule recently issued by the US Securities and Exchange Commission (“SEC”) that would overhaul the use of derivatives and financial commitment transactions by registered investment companies and business development companies.

Design/methodology/approach

This article summarizes the various aspects of the proposed rule, discusses the elements of the proposed rule in greater detail, explains the effect of the proposed rule on existing guidance from the SEC and its staff, and notes the potential transition period for any final rule.

Findings

While the proposed rule is subject to public comment and subsequent consideration by the SEC and its staff, if the proposed rule is adopted in its current form it would result in sweeping changes for registered investments companies and business development companies.

Originality/value

This article contains a detailed overview of a recent SEC rule proposal regarding the use of derivatives by registered investment companies and business development companies and practical guidance from experienced asset management lawyers.

Article
Publication date: 3 May 2016

Michael Rosella, Bill Belitsky and Alexandra Marghella

To discuss a September 22, 2015 Securities and Exchange Commission (“SEC”) proposal for a set of broad and sweeping rules mandating that open-end mutual funds and exchange-traded…

329

Abstract

Purpose

To discuss a September 22, 2015 Securities and Exchange Commission (“SEC”) proposal for a set of broad and sweeping rules mandating that open-end mutual funds and exchange-traded funds (“ETFs”) develop and implement formalized and written liquidity risk management programs (“LRMPs”).

Design/methodology/approach

Describes the purpose of an LRMP, the six “liquidity buckets,” the nine factors that must be considered in determining an instrument’s liquidity, the need to continuously monitor the liquidity of each position, the set of eight mandated factors used to assess a fund’s liquidity risk, the requirement for a fund to define a three-day liquid asset minimum, the role of the fund’s board of directors, a separate rule permitting “swing pricing” to adjust net asset value to take into account the costs of unexpected redemptions or cash infusions, disclosure requirements, and proposed compliance dates.

Findings

In proposing this new program, the SEC stated that its goal was to enhance effective liquidity risk management practices by funds and thereby reduce the risk that funds will be unable to meet redemptions under reasonably foreseeable stressed market conditions.

Originality/value

Expert guidance by experienced financial services lawyers.

Article
Publication date: 2 May 2017

Rachael Leah Schwartz, Domenick Pugliese, Marguerite Bateman and Kimberly Vargo

To provide an overview of the US Securities and Exchange Commission’s (SEC) recently adopted rule 22e-4 (Rule 22e-4) under the Investment Company Act of 1940, as amended (1940…

382

Abstract

Purpose

To provide an overview of the US Securities and Exchange Commission’s (SEC) recently adopted rule 22e-4 (Rule 22e-4) under the Investment Company Act of 1940, as amended (1940 Act) regarding investment company liquidity risk management programs.

Design/methodology/approach

Reviews and summarizes the specific requirements of Rule 22e-4 to better enable investment companies and their boards to comply by the general compliance date of December 1, 2018 (smaller complexes have until June 1, 2019).

Findings

The SEC clarifies that each fund should tailor its particular Program to ensure that it is adequately assessing and managing its specific liquidity risk based on its investment strategies and risks; however, it is not expected that a fund would eliminate all adverse impacts of liquidity risk. In addition, under the final rule, while the board does have certain duties and responsibilities with respect to certain aspects of a fund’s Program, the SEC pared back much of what had been in the Proposing Release to ensure that the board’s role remains one of oversight and not management.

Practical implications

Although the compliance date does not occur for almost two years, funds and their boards should begin reviewing the Rule 22e-4 requirements now and developing their Program.

Originality/value

Practical guidance from experienced investment management attorneys that provides insight into expectations for compliance with Rule 22e-4.

Details

Journal of Investment Compliance, vol. 18 no. 1
Type: Research Article
ISSN: 1528-5812

Keywords

Article
Publication date: 1 October 1938

AT the Conference at Folkestone of the London and Home Counties Branch of the Library Association, Mr. Jast gave one more example of his old fire and vigour in a paper which he…

Abstract

AT the Conference at Folkestone of the London and Home Counties Branch of the Library Association, Mr. Jast gave one more example of his old fire and vigour in a paper which he entitled Publishers and Librarians. No doubt in other pages than ours the text will be given in full. Here, in summary, we may say that he dealt with some of the needs of librarians and readers for well‐produced editions of good books which for some reason were obtainable only in double‐columned small type or otherwise almost unreadable or at any rate unattractive form. He instanced Disraeli's Curiosities of Literature. He urged that if a sufficient number of public and other librarians represented this want to publishers, promising that the libraries would support such an edition, it was unlikely that the request would be ignored. A further suggestion arose from the established fact that in the welter of editions of certain books many were ill‐produced and unworthy to be placed in the hands of unsuspecting bookbuyers. Robinson Crusoe was a case in point, and as many parents desired their sons to read this they were often persuaded to buy editions which were unsuitable. Here he made a suggestion which is entirely practicable: that the Library Association should examine all of the common classics for form and for textual accuracy—a feature in which he alleged that some were deficient—and fix on suitable editions, allowing the publisher to add to their title‐pages “approved by the Library Association.” We seize upon this point first because there is nothing Utopian about it. It is a work that ought to be done.

Details

New Library World, vol. 41 no. 4
Type: Research Article
ISSN: 0307-4803

Article
Publication date: 1 August 1935

IDEAL methods of Library service; this, in simple translation is the purpose before the Library Association Conference at Manchester this year. The first thing that strikes any…

Abstract

IDEAL methods of Library service; this, in simple translation is the purpose before the Library Association Conference at Manchester this year. The first thing that strikes any observer is the great variety of current library work. There was a day, so recent that fairly young men can remember it, when a Library Association Conference could focus its attention upon such matters as public library charging systems, open access versus the indicator, the annotated versus the title‐a‐line catalogue, the imposition of fines and penalties; in short, on those details of working which are now settled in the main and do not admit of general discussion. All of them, too, it will be observed, are problems of the public library. When those of other libraries came into view in those days they were seen only on the horizon. It was believed that there was no nexus of interest in libraries other than the municipal variety. Each of the others was a law unto itself, and its problems concerned no one else. The provision of books for villages, it is true, was always before the public librarian; he knew the problem. In this journal James Duff Brown wrote frequently concerning it; before the Library Assistants' Association, Mr. Harry Farr, then Deputy Librarian of Cardiff, wrote an admirable plea for its development. Wyndham Hulme once addressed an annual dinner suggesting it as the problem for the younger librarians. Carnegie money made the scheme possible. But contemporaneously with the development of the Rural Library system, which now calls itself the County Library system as an earnest of its ultimate intentions, there has been a coming together of the librarians of research and similar libraries. We have a section for them in the Library Association.

Details

New Library World, vol. 38 no. 2
Type: Research Article
ISSN: 0307-4803

Article
Publication date: 1 February 1990

R.K. Jain and S. Chandra

Epoxy resins are compounds which contain in their molecule more than one 1,2 epoxy group capable of undergoing polyreactions, referred to as curing reactions. The presence of…

Abstract

Epoxy resins are compounds which contain in their molecule more than one 1,2 epoxy group capable of undergoing polyreactions, referred to as curing reactions. The presence of epoxy groups may be either internal, terminal or on cyclic structures. Polyreactions take place at varying temperatures from low room temperature cure to high temperature cure systems upon addition of curing agents such as amines, amides or carboxylic acid anhydrides. The uncured resins which range from low viscosity liquids to high melting solids, soluble in organic solvents, become insoluble, infusible hard materials on curing due to crosslinked structure of the cured products.

Details

Pigment & Resin Technology, vol. 19 no. 2
Type: Research Article
ISSN: 0369-9420

Article
Publication date: 1 May 1936

THE June conference at Margate is so near that we must needs be pre‐occupied with it at the moment although two months ago we were able to give an anticipatory description of the…

Abstract

THE June conference at Margate is so near that we must needs be pre‐occupied with it at the moment although two months ago we were able to give an anticipatory description of the programme. The protracted and cold winter, culminating in the most “perishing” April of the century, possibly of any century since the Great Ice Age, seems on the threshold of May to have dissolved at last in warmer weather. Margate is a lady in the sun, but perhaps something else under cloud, and wise people take warm clothes when they visit her. We hope, however, that they will not be necessary and that for some hundreds of our readers Margate air will be an invigorating experience.

Details

New Library World, vol. 38 no. 10
Type: Research Article
ISSN: 0307-4803

Article
Publication date: 1 March 1984

Government and IT ‐ In spite of all the lip service paid by Government to making a business of information and encouraging increases in the amount of information available online…

Abstract

Government and IT ‐ In spite of all the lip service paid by Government to making a business of information and encouraging increases in the amount of information available online, the Department of Trade is still indulging in foot dragging about online access to tradenames. Since 1979, tradenames have been held on computer and I was told in that year (NLW, November 1979) by the Department of Trade that an index to tradenames would be produced shortly and sold to libraries and others on COM‐fiche. Now two computer indexes are poised for the public market, but it seems the Department of Trade is once again playing a will we? won't we? game, because if the Department went online, the others might not bother. The first independent computer data base is with Datema Limited who have carried out very successful field trials with Laurence Tagg in Newcastle‐upon‐Tyne Business Library, as well as at Sheffield and the Science Reference Library; the second data base is with Compu‐Mark (UK) Limited in London.

Details

New Library World, vol. 85 no. 3
Type: Research Article
ISSN: 0307-4803

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