Advisers

FYI: Fund Sub-Adviser Retained Without Shareholder Vote

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FYI: Under a no-action letter issued this week, a fund will be allowed to retain an interim sub-adviser during an additional 60 days when, despite diligent efforts, the fund was unable to garner the requisite shareholder proxies to approve the sub-adviser during the 150-day period allowed under Investment Company Act Rule 15a-4. During the additional 60-day period, the adviser will be required to bear all proxy solicitation expenses and to waive a portion of its advisory fee equal to the fee payable to the sub-adviser under the interim sub-advisory agreement. No-action letter: https://www.sec.gov/divisions/investment/noaction/2017/nuveen-fund-advisors-15a-062017.htm. * * *

Advisers

FYI: Updates to FAQs on Form ADV

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FYI: The Division of Investment Management has posted new or revised FAQs on the following items of Form ADV, many of which relate to ADV amendments being implemented starting October 1, 2017: Form ADV: Item 1.I (several questions relating to reporting social media) Form ADV: Item 1.J (new question relating to outsourced CCOs) Form ADV: Item 1.O (relating to advisers with over $1 billion in balance sheet assets) Form ADV: Item 5.D (relating to reporting categories of clients) Form ADV: Item 5.K (relating to new Item 5.K. reporting separately managed account clients) Form ADV: Item 7.B (relating to Schedule D […]

Advisers

FYI: Standards of Conduct for IAs and BDs

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FYI: SEC Chairman Jay Clayton issued a public statement requesting comment on issues surrounding what standards of conduct should apply to investment advisers and broker-dealers, turning attention once again to the many difficult issues in this arena that have been under review for over a decade. According to the Chairman’s statement, the SEC’s consideration this time will include “constructive engagement” with the Department of Labor as it continues its analysis of similar issues from its own perspective. It is unclear what “constructive engagement” between the SEC and DOL will mean in practice, but the Chairman expressed his belief that clarity […]