Small Funds Content

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...

[33411] April 1, 2021 TO: ICI Members SUBJECTS: Audit and Attest Closed-End Funds Fund Accounting & Financial Reporting RE: SEC Issues Dear CFO Letter for Investment Companies On March 30, 2021 the staff of the Chief Accountant?s Office in the Division of Investment Management issued...

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...

[33345] March 23, 2021 TO: ICI Members SUBJECTS: Compliance Disclosure Transfer Agency RE: SEC Institutes Proceedings to Determine Whether to Approve or Disapprove NYSE's Proposed Rule Change to Move Responsibility to FINRA for Processing Fee Schedule As we previously reported to you...

[33273] March 19, 2021 TO: AML Compliance Working Group Chief Compliance Officer Committee Operations Committee Transfer Agent Advisory Committee SUBJECTS: Anti-Money Laundering Compliance Operations Transfer Agency RE: New Fraud Prevention Resources Available on ICI's Website We are...

[33272] March 19, 2021 TO: ICI Members Accounting/Treasurers Committee SEC Rules Committee Security Valuation Operations Committee SUBJECTS: Compliance Fixed Income Securities Fund Accounting & Financial Reporting Valuation RE: SEC FAQ Addresses Rule 2a-5 Compliance Date and Effect on...