• Adoption of Rule 206(4)-7 -- Investment Adviser Compliance Programs
  • January 6, 2004
  • Law Firm: Sutherland Asbill & Brennan LLP - Washington Office
  • On December 17, 2003, the Securities and Exchange Commission ("SEC") published rules requiring SEC-registered investment advisers ("Advisers") to: adopt and implement written policies and procedures reasonably designed to prevent violation of the Investment Advisers Act of 1940, as amended (the "Advisers Act") and the rules adopted by the SEC thereunder; review such policies and procedures, at least annually, for their adequacy and the effectiveness of their implementation; and designate a chief compliance officer to be responsible for administering the policies and procedures.