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Asset Management ADVocate

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SEC Scrutinizes Evaluation of Fund Advisory Contracts

The SEC recently imposed sanctions against an investment adviser and board members of a mutual fund for their failure to evaluate thoroughly an advisory contract in violation of Section 15(c) of the Investment Company Act.

The Gartenberg factors are still the appropriate framework to use during the evaluation of advisory contracts, but approval should reflect a thorough and thoughtful pr

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SEC Division of IM Issues Guidance Update on Personal Securities Transactions

On June 26th, the Securities and Exchange Commission's Division of Investment Management issued IM Guidance Update No.

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Liquidity: An Afterthought to the Investment Company Act

SEC Commissioner Kara Stein gave a thoughtful speech at the Brookings Institution the other day, identifying some urgent questions regarding mutual fund regulation. I am simpatico with many of the views expressed in her speech.

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Using Money Fund Gates in a (and as a) Clutch

Many have found Question 28 of the SEC staff's 2014 Money Market Fund Reform Frequently Asked Questions frustrating.

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Investment Advisers Act Compliance Developments in 2015

The year 2015 is shaping up to have an unusual focus on the center of that string of relationships tracing the path from end-investor to asset class -- that is, the nuts and bolts of asset management "operations." Click here

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Why Intermediaries Can Stop Worrying About Money Fund Liquidity Fees—Part Three

Currently, managers and directors of money market funds are wrestling with the question of how to make certain that every intermediary selling their funds can implement a liquidity fee.

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Form BE-10 Reminder… Plus New FAQs for Funds

Update: For many filers, May 29 was the deadline for Form BE-10 to be filed with the Department of Commerce's Bureau of Economic Analysis. Certain others have obtained an extension, and those with 50 or more foreign affiliates may have until June 30.

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Transfer and Sub-Transfer Agent Cybersecurity: Implementing SEC Guidance

The cybersecurity threats faced by mutual fund transfer agents (TAs) and sub-transfer agents (Sub-TAs) are unique because their information technology (IT) networks house a massive amount of personally identifiable information (PII) belonging to the funds they serve (Fund PII).* In its recent IM Gu

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Welcome to Asset Management ADVocate!

Welcome to our new blog, in which you will find unique analysis and insights into legal developments affecting asset managers and investment funds in the United States.

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