The following are summaries of key developments in the investment management industry. More detailed coverage of these and other topics can be found here.

 SEC Proposes Rule Regulating Derivatives

The Securities and Exchange Commission (SEC) in December proposed Rule 18f-4 under the Investment Company Act of 1940, as amended (the Act), to provide a comprehensive approach to the regulation of the use derivative instruments by mutual funds, closed-end funds, exchange-traded funds, and business development companies (collectively, Funds).

SEC Amends Money Market Rules, Removing References to Credit Ratings, Eliminating Exclusion from Issuer Diversification Provisions

The SEC adopted rule amendments to eliminate references to credit ratings in Rule 2a-7 and Form N-MFP under the Investment Company Act of 1940, as amended (the 1940 Act). The SEC also amended issuer diversification provisions to eliminate an exclusion for securities subject to a guarantee issued by a non-controlled person.

U.S. Court of Appeals for the District of Columbia Circuit Dismisses Challenges to SEC’s Political Contribution Rule

The U.S. Court of Appeals for the District of Columbia Circuit recently dismissed a petition brought by the New York Republican State Committee and the Tennessee Republican Party (plaintiffs) requesting direct review of a four-year-old rule, promulgated under the Investment Advisers Act of 1940 (Investment Advisers Act), regulating campaign contributions by investment advisers (Political Contribution Rule).

To learn more about these developments and other investment management news, please contact a member of the Ballard Spahr Investment Management Group or the attorney with whom you regularly work.


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This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.


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