News & Analysis as of

Investment Advisers Act of 1940 Outsourcing

Miller Canfield

2024 Regulatory Update for Investment Advisers

Miller Canfield on

In 2023, the Securities and Exchange Commission issued various proposed rules on regulatory changes that will affect SEC-registered investment advisers (RIAs). Since these rules are likely to be put into effect, RIAs should...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Rule on Outsourcing by Investment Advisers

On October 26, 2022, the U.S. Securities and Exchange Commission (SEC) proposed a new Rule 206(4)-11 and amendments to Rule 204-2 under the U.S. Investment Advisers Act of 1940 (Advisers Act), as well as amendments to Form...more

Dorsey & Whitney LLP

SEC Proposes New Oversight Requirements for Certain Services Outsourced by Investment Advisers

Dorsey & Whitney LLP on

The Securities and Exchange Commission (the “SEC”) recently proposed new rule 206(4)-11 and related recordkeeping and reporting requirements (collectively, the “Proposed Rule”) under the Investment Advisers Act of 1940 (the...more

Morgan Lewis

SEC Proposes New Rule Relating to Outsourcing of Services by Investment Advisers

Morgan Lewis on

The US Securities and Exchange Commission recently proposed a new rule and rule amendments that, if adopted as proposed, would require registered investment advisers to meet certain requirements when outsourcing certain...more

Eversheds Sutherland (US) LLP

SEC proposes service provider oversight requirements for investment advisers

On October 26, 2022, the Securities and Exchange Commission (SEC) proposed new Rule 206(4)-11 under the Investment Advisers Act of 1940 (Advisers Act), which would prohibit SEC-registered investment advisers from outsourcing...more

Sullivan & Worcester

SEC Proposes New Rule Requiring Investment Adviser Oversight of Certain Third Party Service Providers

Sullivan & Worcester on

On October 26, 2022, the Securities and Exchange Commission ("SEC") proposed a new rule under the Investment Advisers Act of 1940 ("Advisers Act") to prohibit registered investment advisers from outsourcing certain services...more

ArentFox Schiff

SEC Proposes New Oversight Requirements for Certain Services Outsourced by Investment Advisors

ArentFox Schiff on

On October 26, 2022, the US Securities and Exchange Commission (SEC) proposed a new rule and rule amendments under the Investment Advisors Act that, if passed, would prohibit registered investment advisors from outsourcing...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - A Source of Concern for the SEC — The Outsourcing by Investment Advisers and Funds of Compliance Activities - In a recent National Exam Program Risk Alert (dated November 9, 2015) the U.S....more

Bracewell LLP

SEC Issues Report on Increasing Use of Outsourced Chief Compliance Officers

Bracewell LLP on

In November 2015, the Securities and Exchange Commission (SEC) released its Outsourced CCO Initiative Report. The report addressed the increased trend of outsourcing compliance activities to third-party consultants within the...more

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