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Comments on Procedures for Review of Exemptive Applications Under the Investment Company Act

The IAA supported the objective of the proposal to make the applications process more efficient. The IAA also supported comments made by the Investment Company Institute regarding the expedited review process, transparency on the timeframe for staff action, and concerns on publication of comments and responses.

November 27, 2019

Keywords: Investment Company Act

Categories & Topics: Compliance, Registered Funds

Comments on Investment Company Act Cross-Trading Rule 17a-7

The IAA called on the SEC to modernize the Investment Company Act cross-trading rule, recommending that the SEC reverse a new definition of “readily available market quotations,” amend the rule to codify relief related to board oversight, and recognize the protections afforded to fund shareholders by the Advisers Act fiduciary duty.

April 11, 2021

Keywords: Cross Trading, SEC, Valuation

Categories & Topics: Brokerage & Trading, Business Ops/HR, Registered Funds

Response to FTC Proposal to Aggregate Acquisitions for HSR Filings

We responded to an FTC proposal to redefine “person” under Hart-Scott Rodino premerger notification rules to include “associates.” Investment managers would need to aggregate acquisitions in an issuer across all clients to determine if the manager reaches the filing threshold. We argue that aggregation would harm investors and severely impact an adviser’s ability to meet its fiduciary duty, and that the proposal reflects a fundamental misunderstanding of how advisers treat their separate clients.

February 01, 2021

Keywords: Federal Trade Commission, Hart-Scott-Rodino Proposal on Aggregation, Registered Funds

Categories & Topics: Business Ops/HR, Industry Trends, Industry-Level, Registered Funds

Comments on SEC Fair Value Proposal

The IAA generally supported the proposal but recommended more flexibility regarding the reporting requirements, making the definition of “readily available market quotation” reflect current valuation practices, and flexibility for a fund board to assign the fair value determination to the fund’s primary adviser or sub-adviser.

July 21, 2020

Keywords: Fair Value, Investment Company Act, Valuation

Categories & Topics: Compliance, Registered Funds, Valuation

Comments on the SEC Derivatives and Sales Practice Rules

The IAA generally supported the proposed derivatives rule, with certain modifications to reduce unnecessary burdens on advisers. The IAA strongly opposed the proposed sales practice rule for investment advisers related to retail investor transactions in leveraged/inverse investment vehicles because it is both duplicative of and inconsistent with the principles-based approach to fiduciary duty.

April 30, 2020

Keywords: Derivatives, fiduciary duty), Investment Company Act

Categories & Topics: Compliance, Fiduciary, Registered Funds

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