Division of Investment Management

The staff of the SEC’s Division of Investment Management warned against “disclosure creep” invading fund prospectuses in regulatory guidance posted in June 2014.

In reviewing registrant filings, the staff cited a “significant number of prospectuses,” which contained disclosure that is “complex, technical and duplicative.”  Moreover, it found many Summary Sections to be “unnecessarily long.”


Acknowledging the growing demand by consumers for information through social media, the Division of Investment Management set some ground rules on how investment advisers can use social media and publish advertisements featuring public commentary about them from social media sites.

Click here to read Morrison & Foerster’s summary on the Socially Aware blog. 

The SEC’s Division of Investment Management recommends that fixed income fund advisers take steps to assess portfolio risk in light of “potential market volatility” and review the adequacy of related prospectus disclosures.

In particular, the staff suggests that fund advisers “consider taking” the following steps:

  • Assess and stress-test liquidity during normal and stressed environments, taking