Amy R. Doberman

2 months ago | jdsupra.com | Amy R. Doberman

Once upon a time, in 1994, when I was a young lawyer in the SEC’s Division of Investment Management (Division), Office of Chief Counsel, we received a request to modify a previously granted but totally impractical no-action position addressing Rule 17a-7 under the Investment Company Act of 1940 (the 1940 Act), which allowed funds to cross-trade municipal securities.

Jan 24, 2025 | wilmerhale.com | Amy R. Doberman

In an article published in The Investment Lawyer, Partner Amy Doberman explains the history of cross-trading guidance and relief, the subsequent reluctance to adopt cross-trading and the eventual interpretive positions and statements that effectively ended cross-trading practices, among other topics.

Oct 11, 2023 | mondaq.com | Matthew Kulkin |Timothy Silva |Gretchen Passe Roin |Amy R. Doberman

The Commodity Futures Trading Commission (CFTC or Commission) recently proposed amendments to CFTC Regulation 4.7 (the Proposed Rule) that would impact long-standing exemptions from certain compliance requirements for commodity pool operators (CPOs) and commodity trading advisors (CTAs).1 The CFTC prepared the Proposed Rule to "update" Regulation 4.7 "after a careful review of the existing language and structure of Regulation 4.7, and considering the clear public and regulatory interest of...