February 2006 Archives
NASD and MSRB Issue Joint Statement on Consistent Sales Practice Rules for 529 Plans and Mutual Funds
On February 22, 2006, NASD and the Municipal Securities Rulemaking Board (MSRB) issued a joint statement announcing their intent to cooperate to harmonize the MSRB rules and the NASD rules applicable to sales practices for 529 Plans and mutual funds. Because 529 Plans are municipal securities, they are primarily regulated by the MSRB. However, 529 Plans typically use registered mutual funds as their primary investment vehicle, and most municipal securities dealers that sell 529 Plans are also NASD members.
NASD and NYSE Adopt New Requirements Regarding Member’s AML Compliance Programs
NASD and NYSE have recently issued notices describing new requirements regarding member firms’ anti-money laundering (AML) compliance programs. On February 3, 2006, NYSE issued Information Memo 06-4 and on February 10, 2006, NASD issued Notice to Members 06-07 describing the changes to their respective AML compliance program requirements. The new NYSE requirements are now in effect, and the new NASD requirements become effective on March 6, 2006.
SEC Reminds Mutual Funds and Insurance Company Separate Accounts to Obtain EDGAR Indentifiers for Series, Classes and Insurance Contracts
On January 30, the Securities and Exchange Commission issued a notice reminding mutual funds and insurance company separate accounts that they must:
(i) obtain EDGAR identifiers for their series and classes (or insurance contracts, in the case of separate accounts); and
(ii) identify in certain EDGAR filings the series and classes (or contracts) for which the particular filing is being made.
Registrants should obtain their identifiers prior to February 6. On and after February 6, EDGAR will not accept filings without required series and class (contract) identifiers.
Investment Management FYI is a service of the Investment Management Practice of Morgan Lewis. If you have any questions concerning these important legal developments, please contact any Morgan Lewis attorneys.