Author:Nora Klemmer

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Amendments to the Names Rule
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Spot Bitcoin ETFs – Coming to an Exchange Near You (Maybe)!
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The SEC’s New Rules for Private Fund Advisers: A Dose of Transparency for the Private Markets
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SEC Passes New Money Market Fund Rules: Swing Pricing is Out and Mandatory Liquidity Fees are In

Amendments to the Names Rule

By: Abigail Hemnes, George Zornada, Franklin Na, Donela M. Qirjazi and Christine Mikhael

On 20 September 2023, the SEC adopted amendments to the Names Rule (35d-1) that will significantly expand the Names Rule’s applicability and will require all funds to consider whether changes are required to their names, 80% policies, disclosures, compliance tests, and reporting requirements.

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Spot Bitcoin ETFs – Coming to an Exchange Near You (Maybe)!

By: Rich Kerr, Peter Shea, Andrew Hinkes, and Brian Doyle-Wenger

On 29 August 2023, the United States Court of Appeals for the District of Columbia Circuit (Court) issued a decision siding with Grayscale Investments, LLC (Grayscale) and vacated the U.S. Securities and Exchange Commission’s (SEC) rejection of the NYSE Arca’s (NYSE) request for approval of a listing rule that would permit it to list shares of the Grayscale Bitcoin Trust (GBT) for trading.

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The SEC’s New Rules for Private Fund Advisers: A Dose of Transparency for the Private Markets

By: Ken Holston, TJ Bright, Pablo Man, Matthew Mangan, Chris Phillips-Hart, Annabelle North

On August 23, 2023, the SEC adopted sweeping new rules that will impose substantial regulation on the management and operation of private funds by investment advisers.  The rules appear to be somewhat less burdensome than the rules originally proposed in February 2022.  

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SEC Passes New Money Market Fund Rules: Swing Pricing is Out and Mandatory Liquidity Fees are In

By: Max Black, Michael Davalla and Cal Gilmartin

On July 12, 2023 the SEC adopted rules applicable to money market funds (“MMFs”). The new rules change: (i) liquidity thresholds; (ii) liquidity fees and redemption gates; (iii) options for responding to negative interest rate environments; and (iv) reporting obligations. Importantly, the SEC declined to impose swing pricing mechanisms on MMFs depending on their net redemptions. The new rules institute mandatory liquidity fees for institutional prime funds and institutional tax exempt funds.

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