In addition to the creation of new funds and products, Fred regularly advises clients with respect to ongoing operations, such as periodic reporting and filing, annual reviews and approvals, exemptive applications, no-action letters, advertising, U.S. Securities and Exchange Commission (SEC) examinations and compliance manuals. In the investment company transactional area, Fred counsels in mergers and acquisitions of mutual funds and separate accounts, reorganizations and addition or deletion of portfolios.
Honorable H. Emery Widener, Jr., U.S. Court of Appeals - Fourth Circuit.
Counseled life insurance companies on the redesign of registered separate account products.
Counseled a coalition of major life insurance companies on evolving state and federal regulations and other legal developments.
Counseled on swap status of structured settlements and cross-border reinsurance.
“We do a lot of cutting-edge work with new products-things that have never been done. People said, ‘The rules are this way. You can’t do it that way.’ But we did it anyway, and it was successful.”
Legal Alert: Fund of funds flexibility - What’s important to BDCs and closed-end funds in the SEC’s rule proposal, including a request for comments on AFFE (January 14, 2019)
On December 19, 2018, the US Securities and Exchange Commission (SEC) issued a release (the Release) proposing new rule 12d1-4 (the Proposed Rule) and related amendments to streamline and enhance the ...
Legal Alert: SEC investment company filings during government shutdown (January 2, 2019)
The Securities and Exchange Commission (SEC) is subject to the current federal government shutdown due to lack of funding, and generally it will follow its “Operations Plan Under a Lapse in ...
Legal Alert: SEC proposes new variable contract disclosure regime (November 6, 2018)
The US Securities and Exchange Commission (SEC or Commission) recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies ...
Legal Alert: SEC permits internet delivery of investment company shareholder reports-including insurance company separate accounts (June 25, 2018)
The Securities and Exchange Commission (SEC) on June 5, 2018, adopted Rule 30e-3 under the Investment Company Act (the Rule), which permits “notice and access” delivery of investment company ...
Legal Alert: New York Proposes Best Interest Standard for Life and Annuity Sales Alongside NAIC Proposal for Annuities (January 4, 2018)
On December 27, 2017, the New York Department of Financial Services (NYS-DFS), the regulatory authority for the insurance industry in New York, published a proposal (New York Proposal) to add a “best ...
Legal Alert: SEC Staff Provides Guidance on Disclosure of Sales Load Variations and Filing of New Share Classes in Light of the DOL Fiduciary Rule (January 5, 2017)
I. Introduction On December 16, 2016, the Division of Investment Management (IM) of the Securities and Exchange Commission (SEC) published a Guidance Update (the Guidance) providing guidance on ...
Legal Alert: NAIC Adopts Revisions to Actuarial Guideline 49 (December 16, 2016)
On December 13, the National Association of Insurance Commissioners (NAIC) Executive (EX) Committee and Plenary adopted revisions to Actuarial Guideline 49 (AG 49) with an effective date of March 1, ...
Legal Alert: SEC Adopts Rules to Modernize Information Reported by Registered Investment Companies (December 8, 2016)
On October 13, 2016, the Securities and Exchange Commission (the SEC) issued a release adopting final rules to modernize and enhance the reporting and disclosure of information by registered ...
Legal Alert: SEC Adopts Liquidity Risk Management Rules for Mutual Funds and Other Open-End Investment Companies (November 14, 2016)
On October 13, 2016, the SEC approved new Rule 22e-4 under the Investment Company Act of 1940, as amended (the 1940 Act), which will require certain open-end investment companies other than money ...
Legal Alert: NAIC Life Actuarial (A) Task Force Approves Revisions to Actuarial Guideline 49 for Exposure and Comment (October 27, 2016)
On October 20, the NAIC Life Actuarial (A) Task Force (LATF) of the Life Insurance and Annuities (A) Committee met and approved proposed revisions to Actuarial Guideline 49 (AG 49) for exposure and ...
Modernizing The Variable Contract Disclosure Regime (December 2018)
The US Securities and Exchange Commission recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies that reflects almost a decade ...
A Compromise on Indexed Universal Life Insurance Visuals (July 7, 2015)
On June 18, 2015, the National Association of Insurance Commissioners Executive Committee/Plenary adopted new Actuarial Guideline XLIX (AG 49), which for the first time sets forth uniform standards ...
Securities or Not: Uncertainties Remain For Fixed Insurance Products After Dodd-Frank (October 18, 2010)
Reprinted with permission Securities Regulation & Law Report
Variable Insurance Products (1998)
The Investment Company Regulation Deskbook
Member, American Bar Association
Member, Federal Bar Association
Member, Federal Affairs and State Affairs Committees, Insured Retirement Institute
Member, District of Columbia Bar
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