Publications

This edition of the Simpson Thacher Registered Funds Alert discusses recent developments in the registered funds industry, including two recent SEC enforcement actions involving allegations of deficiencies in the Section 15(c) process, the inconsistency with which the SEC brings charges against chief compliance officers, the potential impact of a recent Ninth Circuit decision on the ability of shareholders of mutual funds to bring suits against trustees and investment advisers, as well as a Second Circuit decision that may make purchasing loans originated by national banks more complicated. In addition, this Alert discusses a recent administrative proceeding regarding the use of “may” instead of “will” in disclosure documents and reliance on advice from compliance consultants, a recent FAQ regarding ownership rights and the Shanghai-Hong Kong Stock Connect Program, and a summary of our comment letter to the SEC on its proposed amendments to investment company reporting requirements. Finally, we report on notable transactions that occurred in the second quarter of 2015, including M&A transactions and closed-end fund initial public offerings.