LORNA A. SCHNASE

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. * * *

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 […]