IAA & ICI Develop Sub-Adviser Due Diligence Review Materials
A working group comprised of members of the Investment Company Institute, the Investment Adviser Association, and legal counsel to independent directors developed this questionnaire and certification letter, which are intended to assist members in sub-adviser due diligence reviews, including reviews pursuant to Rule 38a-1 under the Investment Company Act of 1940.
The questionnaire and certification letter are designed for annual, rather than initial, use. Advisers evaluating whether to select a sub-adviser in the first instance may wish to use different questionnaires and certifications. In addition, the documents are not intended for solicitation of all of the information requested in connection with an investment company board's review of an advisory contract under Section 15(c) of the Investment Company Act. These documents are not intended to endorse particular questions or practices and because of different business operations among member firms, no one questionnaire or certification may be appropriate for every firm. In addition, the documents do not constitute, and should not be considered a substitute for, legal advice.