3+ hour, 31+ min ago  (315+ words) On Monday, the SEC staff issued a no-action letter (the "No-Action Letter), in which the staff stated that it would not recommend enforcement action if a registered open-end fund ("Open-End Fund), whose primary investment adviser or sub-adviser is an Adviser…...

5+ day, 3+ hour ago  (343+ words) I. Why the DOJ Targeted IBM as a Federal Contractor Separately, the government contended that IBM allocated costs of these practices to its federal contracts and sought reimbursement for them, a second, independent theory of FCA liability that does not depend…...

5+ day, 8+ hour ago  (174+ words) The Statement appears to build on the SDNY's opinion by providing a detailed explanation of the activities that Covered User Interfaces may engage in without registering as broker-dealers, and the conditions they must meet. We consider those activities and conditions…...

1+ week, 1+ day ago  (330+ words) Proposed remedies and binding commitments were likewise central to the analysis. Across all five cases, courts were receptive to arguments that binding, practicable commitments changed the competitive effects calculus in the real-world." Several opinions faulted the agencies for modeling harm…...

2+ week, 5+ day ago  (389+ words) Dechert's private credit and asset-backed finance (ABF) team returned to Las Vegas from February 2326 for SFVegas 2026, the structured finance industry's annual cannot-miss event. Although what happens in Vegas is supposed to stay in Vegas, here are a few highlights fit…...

2+ week, 6+ day ago  (1603+ words) A 401(k) Plan "Alternative" Proposal: Will DOL Safe-Harbor Provide Smooth Sailing? Dechert A 401(k) Plan "Alternative" Proposal: Will DOL Safe-Harbor Provide Smooth Sailing? On March 31, 2026, the Department of Labor (DOL) issued a proposed regulation (the Proposed Regulation) that addresses the duties that…...

3+ week, 6+ day ago  (330+ words) Within 30 days of the March 2026 EO's issuance, or by April 25, 2026, federal agencies must include a clause in all federal contracts, subcontracts, and lower-tier subcontracts requiring that the contractor agree to the following: 7 It is worth highlighting that the March 2026 EO…...

4+ week, 2+ hour ago  (39+ words) The authors would like to thank Andrew Olivei for his contributions to this On Point. San Francisco +1 415 262 4530 Washington, D. C. +1 202 261 3454 New York +1 212 641 5626 New York +1 646 731 6185...

1+ mon, 1+ day ago  (347+ words) Dechert LLP's global finance team has been recognized by Global Capital in its European Securitization Awards 2026, where a Dechert deal " Ares Management's debut European direct lending CLO, the Ares European Direct Lending CLO 1 " was named "CLO Deal of the Year…...

1+ mon, 3+ day ago  (523+ words) In this edition of Dechert's Securities & Derivative Litigation Report, we: The Ninth Circuit, the leading forum for securities litigants in 2024, saw a 30% decline in securities actions, 4falling to second place behind the Second Circuit in 2025. Favorable precedent and a high concentration…...