Investment Services Regulatory Update - October 2017

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New Rules, Propsed Rules, Guidance and Alerts -

SEC STAFF GUIDANCE AND ALERTS -

SEC Staff Extends No-Action Relief on Auditor Independence and the “Loan Provision” -

On September 22, 2017, the staff of the SEC’s Division of Investment Management (the Staff) issued a follow-up no-action letter (the Follow-Up Letter) to Fidelity Management & Research Company (FMR) extending its previous assurances, set forth in a letter dated June 20, 2016 (the Initial Letter), that, subject to certain conditions set forth in the Initial Letter, it would not recommend enforcement action to the SEC if a registered fund or other entity (a Fidelity Entity) in its “investment company complex” (as defined by Regulation S-X) employs a registered public accounting firm (an Audit Firm) that has relationships causing non-compliance with certain independence requirements under the so-called “Loan Provision

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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