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SEC Issues No-Action Letters to Ease U.S. and MiFID II Compliance; EC Issues Guidance on MiFID II Advisers’ Receipt of Research from Non-EU Brokers

On October 26, 2017, the SEC staff issued three no-action letters to, respectively, the Investment Company Institute (the “ICI Letter”), the Securities Industry and Financial Markets Association’s Asset Management Group (the “SIFMA-AMG Letter”) and SIFMA (the “SIFMA Letter”). The three letters provide greater certainty to market participants regarding compliance with U.S. law as they seek to comply with the European Union’s updated Markets in Financial Instruments Directive (“MiFID II”) by January 3, 2018.

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The AIFMD Third Country Passport – An Update

Practices: Asset Management

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The European Securities and Markets Authority published on 19 July 2016 its final advice to the European Commission on the extension of the marketing passport under the Alternative Investment Fund Managers Directive to 12 non-EEA countries, including the United States. This Alert considers the opportunities available to managers under the marketing passport, and the implications of obtaining it.

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