Ropes & Gray’s Investment Management Update: August 2011

The following summarizes recent legal developments of note affecting the investment management industry:

SEC Adopts Final Rule for Large Trader Reporting System

On July 26, 2011, the Securities and Exchange Commission ("SEC") adopted a large trader reporting system that will require "large traders" to identify themselves to the SEC and provide the SEC with information about their businesses and their affiliates. The new system also imposes recordkeeping, reporting and limited monitoring requirements on broker-dealers that hold accounts for large traders. The large trader system was adopted substantially as it was proposed in April 2010, though we have noted some key differences between the proposed and final rules below. Our more detailed alert on the proposed system, including Rule 13h-1 under the Securities Exchange Act of 1934 (the "Exchange Act") and new Form 13H, can be found here. The adopting release for the large trader reporting system can be found here