CCO Advisory Issues Subcommittee Content

On March 18, 2021, the US Securities and Exchange Commission (SEC or Commission) adopted interim final form amendments to implement the disclosure and submission requirements of the Holding Foreign Companies Accountable Act (HFCA Act), which go into effect on May 5, 2021. The SEC...

[33399] March 29, 2021 TO: ICI Members ICI Global Members SUBJECTS: Audit and Attest Compliance Disclosure International/Global RE: SEC Adopts Form Amendments to Implement the Disclosure and Submission Requirements of the Holding Foreign Companies Accountable Act The US Securities and...

[33503] April 26, 2021 TO: ICI Members SUBJECTS: Compliance Disclosure Fund Accounting & Financial Reporting RE: SEC Staff Updates Fund Reporting FAQs to Address the Computation of Certain Securities Lending Information on Form N-CEN The Division of Investment Management of the...

In December, the SEC adopted new Rule 2a-5 (the “fair value rule”) under the Investment Company Act, which addresses the fair valuation responsibilities of funds and their boards and advisers.

[33448] April 12, 2021 TO: ICI Members ICI Global Members SUBJECTS: Compliance Financial Stability Operations RE: LIBOR Update: New York Governor Signs LIBOR Tough Legacy Legislation On April 6, New York Governor Andrew Cuomo signed legislation to provide replacement benchmark rates...

[33487] April 19, 2021 TO: ICI Members Investment Company Directors SUBJECTS: Compliance Disclosure ESG Fund Governance Investment Advisers Operations Portfolio Oversight Transfer Agency RE: SEC Reopens Comment Period for Its 2016 Universal Proxy Proposal In 2016, the SEC proposed...

[33486] April 19, 2021 TO: ICI Members Investment Company Directors SUBJECTS: Compliance Disclosure Fund Accounting & Financial Reporting Fund Governance Investment Advisers Operations Portfolio Oversight Risk Oversight Transfer Agency RE: SEC Staff Announces Termination of March 2020...

[33457] April 14, 2021 TO: ICI Members Chief Compliance Officer Committee Investment Advisers Committee Registered Fund CPO Advisory Committee SUBJECTS: Compliance CPO/CTA Derivatives Intermediary Oversight Investment Advisers RE: New NFA Rule and Interpretive Notices Regarding CPOs...

To assist funds in implementing new Rule 12d1-4 under the Investment Company Act of 1940, attached are two sample form of Fund of Funds Investment Agreements that can be used between acquiring funds and acquired funds. One version of the form contains footnotes while the other version...