Is this you? As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.
Claim your profile
Articles by Thomas Bogle
Directed Voting No-Action Relief for Registered Funds and BDCs: Practical Takeaways
Summary On September 29, 2026, the staff of the SEC’s Division of Investment Management (IM Staff) issued a no-action letter to the Mutual Fund Directors Forum (MFDF) allowing a registered investment company or business development company (each, a Fund) to implement an investor voting program that permits retail shareholders to give standing instructions to have their shares voted automatically at future shareholder meetings in line with the recommendations of the Fund’s board of directors.
SEC Grants No-Action Relief For Retail Voting Program: Potential Implications For Business Development Companies And Registered Investment Companies
D Dechert More Dechert is a global law firm that advises asset managers, financial institutions and corporations on issues critical to managing their business and their capital – from high-stakes litigation to complex transactions and regulatory matters. We answer questions that seem unsolvable, develop deal structures that are new to the market and protect clients' rights in extreme situations.
FinCEN Delays AML Requirements For Investment Advisers
D Dechert More Dechert is a global law firm that advises asset managers, financial institutions and corporations on issues critical to managing their business and their capital – from high-stakes litigation to complex transactions and regulatory matters. We answer questions that seem unsolvable, develop deal structures that are new to the market and protect clients' rights in extreme situations.
Treasury Issues Final Investment Advisers AML/CFT Program Rule | JD Supra
Key Takeaways Treasury issued a final rule requiring certain investment advisers to establish an AML/CFT Program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Final Rule). The Final Rule applies to registered investment advisers (RIAs) and exempt reporting advisers, but excludes certain RIAs from its scope.
SEC, FinCEN Propose CIP Rules for Investment Advisers | JD Supra
Key Takeaways The Proposed Rule would require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish, document and maintain written customer identification programs (CIPs). The Proposed Rule comes shortly after a separate rule proposal in February 2024 requiring RIAs and ERAs to establish an anti-money laundering/counter-terrorism financing program (AML/CFT Program).
SEC, FinCEN Propose CIP Rules for Investment Advisers
Key Takeaways The Proposed Rule would require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish, document and maintain written customer identification programs (CIPs). The Proposed Rule comes shortly after a separate rule proposal in February 2024 requiring RIAs and ERAs to establish an anti-money laundering/counter-terrorism financing program (AML/CFT Program).
The United States Establishes the Foundation for a New Outbound Investment Regime | JD Supra
In brief. On August 9, 2023, President Biden signed a highly anticipated Executive Order (the “Outbound E.O.”) to establish a U.S. outbound investment regime.
The US Department of Treasury publishes an Advance Notice of Proposed Rulemaking to develop and implement an outbound investment regime that addresses the national security threat posed by countries of concern
Key Takeaways In brief. On August 9, 2023, President Biden signed a highly anticipated Executive Order (the “Outbound E.O.”) to establish a U.S. outbound investment regime.
The U.S. Department of Treasury publishes an Advance Notice of Proposed Rulemaking to initiate a rulemaking process to develop and implement an outbound investment regime that addresses the national security threat posed by countries of concern seeking to
Key Takeaways In brief. On August 9, 2023, President Biden signed a highly anticipated Executive Order (the “Outbound E.O.”) to establish a U.S. outbound investment regime.
FinCEN Corporate Transparency Notice of Proposed Rulemaking: Access to Beneficial Ownership Information and FinCEN Identifiers | JD Supra
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule)1 on December 15, 2022, implementing the requirements of Section 6403 of the Corporate Transparency Act (Act) governing access to and protection of beneficial ownership information (BOI).2 The Act, enacted on January 1, 2021, as part of the Anti-Money Laundering Act of 2020 within the National Defense Authorization Act of 2021, requires FinCEN to promulgate regulations...
FinCEN Corporate Transparency Notice of Proposed Rulemaking: Access to Beneficial Ownership Information and FinCEN Identifiers
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule)1 on December 15, 2022, implementing the requirements of Section 6403 of the Corporate Transparency Act (Act) governing access to and protection of beneficial ownership information (BOI).2 The Act, enacted on January 1, 2021, as part of the Anti-Money Laundering Act of 2020 within the National Defense Authorization Act of 2021, requires FinCEN to promulgate regulations...
FinCEN Corporate Transparency Final Rule: Beneficial Ownership Information Reporting Requirements and the Potential Impact on Financial Institutions and Pooled Investment Vehicles | Dechert LLP - JDSupra
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on September 29, 2022 issued a final rule (Final Rule)1 defining and implementing the beneficial ownership reporting requirements of Section 6403 of the Corporate Transparency Act (Act).2 The Act, enacted on January 1, 2021, as part of the Anti-Money Laundering Act of 2020 within the National Defense Authorization Act of 2021, requires FinCEN to promulgate regulations mandating “reporting companies” to disclose to...
Congress Enacts Significant Changes to the U.S. Anti-Money Laundering Regime | JD Supra
The Anti-Money Laundering Act of 2020 (AML Act), enacted on January 1, 2021 as part of the National Defense Authorization Act for Fiscal Year of 2021 (NDAA), makes several significant changes to U.S. anti-money laundering (AML) laws and regulations. Financial institutions that are subject to U.S. AML requirements under the Bank Secrecy Act (BSA), as well as other entities that have implemented AML compliance programs, must carefully assess the impact of these changes on their current activities.
OFAC Issues Guidance Indicating Aggressive Interpretation of China Military Company Sanctions | JD Supra
On December 28, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) released guidance on the implementation of sanctions targeting securities of Communist Chinese military companies (“CCMCs”) imposed through Executive Order 13959 (“Order”), which was issued by President Trump on November 12, 2020.
SEC Rule Proposal: Good Faith Determinations of Fair Value Under the Investment Company Act | JD Supra
The U.S. Securities and Exchange Commission on April 21, 2020 proposed a long-anticipated framework for fair valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish requirements for good faith determinations of fair value and would address roles and responsibilities for both fund boards and fund advisers relating to fair valuation.
Newsflash: SEC Proposes Fund Valuation Rule | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
SEC Takes Further Action to Assist Funds in Light of COVID-19 Coronavirus Pandemic: Provides Flexibility for Funds and Insurance Company Separate Accounts to Obtain Short-Term Funding | Dechert LLP - JDSupra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
SEC Adopts Amendments to Auditor Independence Rule to Address the “Loan Provision” | JD Supra
The U.S. Securities and Exchange Commission on June 18, 2019 adopted amendments to Rule 2‑01(c)(1)(ii)(A) under Regulation S-X – the so-called “Loan Provision” (Final Rule).1 The Final Rule will become effective on October 3, 2019.
OFAC Issues Important Updates and Clarifications to Russia Sanctions | JD Supra
Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Already signed up? Log in here By using the service, you signify your acceptance of JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources.
SEC Proposes Amendments to Auditor Independence Rule to Address the “Loan Provision” | JD Supra
If adopted, the Proposal would significantly narrow the universe of lending relationships that implicate the Loan Provision and reduce the compliance burden for audit firms and their audit clients. The Proposal would address significant concerns over audit firms’ ability to comply with the Loan Provision with respect to registered investment companies.
FinCEN Issues FAQs for Customer Due Diligence Rule; Compliance Required in May | JD Supra
Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Already signed up? Log in here By using the service, you signify your acceptance of JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources.
FinCEN Issues FAQs for Customer Due Diligence Rule; Compliance Required in May | Lexology
The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 3, 2018 issued Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions (FAQs).1 The FAQs address various issues raised by financial institutions subject to FinCEN’s new customer due diligence requirements (CDD Rule). The FAQs are timely, given the CDD Rule’s May 11, 2018 compliance date is fast approaching.
The Congressional Review Act: Striking a New Balance between Congressional Control and Regulatory Initiative - The Fate of the Leveraged Lending Guidance at Issue | Dechert LLP - JDSupra
The CRA was enacted in 1996 as part of Speaker Newt Gingrich’s “Contract with America.” It was intended to provide a relatively easy-to-exercise method to check administrative action that was not consistent with the desire of Congress. The CRA allows the two houses of Congress to void an agency rule by passing a joint resolution of disapproval by a majority vote of each house followed by signature of the President.
US Imposes Sanctions on Venezuelan Government Securities
Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Already signed up? Log in here By using the service, you signify your acceptance of JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources.
Show More
loading
Actions
Is this you?
As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.Get in touch with Thomas
Contact Thomas, search articles and posts on X, monitor coverage, and track replies from one place.
Learn more about Muck Rack