• SEC Staff Members Highlight Areas of Focus
  • April 3, 2014 | Authors: Peter D. Fetzer; Terry D. Nelson
  • Law Firms: Foley & Lardner LLP - Milwaukee Office ; Foley & Lardner LLP - Madison Office
  • The Staff from the SEC’s Office of Compliance Inspections and Examinations and the Divisions of Investment Management and Enforcement recently discussed their priorities, at the recent compliance and outreach program for investment adviser and investment company senior officers. Key areas of focus for the Staff are:

    • Valuations of illiquid securities;
    • Portfolio reporting;
    • Investment strategies that are contrary to those disclosed to investors;
    • Corporate governance and fees; and
    • Vigilance in the use of service providers, such as the fund accountant, fund administrator, and fund transfer agent.
    With regard to the use of service providers, the Staff illustrated by reference to sub-advisors, noting that if an advisor brings in a sub-advisor that is not familiar with the regulatory regime of the Investment Company Act, the advisor must be very diligent in ensuring that the sub-advisor knows the rules to which it is subject.