CCO Resource Center: Subadvisers
Chief Compliance Officer Committee
Subadviser Oversight Resources
In 2006, a working group of ICI’s members, the Investment Adviser Association, and legal counsel to independent directors of mutual funds developed a sample questionnaire and certification letter to assist advisers in conducting their annual reviews of sub-advisers. Links to these documents are below. In part, these were developed to assist CCOs in fulfilling a fund’s oversight responsibilities under SEC Rule 38a-1.
With respect to the questionnaire and certification letter, the following should be noted:
- As noted above, these are designed for annual use, not the original due diligence of an adviser;
- These documents are not intended for solicitation of all the information needed in connection with an investment company board’s review of an advisory contract under Section 15(c) of the Investment Company Act of 1940;
- These documents are not intended to endorse particular questions or practices; and
- Because of different business operations among ICI member firms, no one questionnaire or certification may be appropriate for every adviser reviewing each of their sub-advisers.
These documents were provided to members of the Institute via ICI Memo No. 20053, dated May 25, 2006.
The documentation provided by ICI that may be accessed by committee and task force members is restricted to members use only and not for distribution or reproduction. Documentation may be used internally at member organizations as needed to facilitate committee and task force initiatives.