SEC Division of Investment Management

The SEC’s Division of Investment Management on April 3, 2015, said that it will not recommend enforcement proceedings against an investment adviser that structures a three-tier fund allowing certain funds to invest in a “Central Fund” established to create operational efficiencies.

Under the proposed structure, the investment adviser will establish a fund of funds that

Fund compliance policies and procedures should address the receipt of gifts or entertainment by fund advisory personnel, according to guidance published by the SEC’s Division of Investment Management.

Section 17(e)(1) of the Investment Company Act of 1940 (1940 Act) generally prohibits first-tier or second-tier affiliates of a registered fund, acting as agent, from accepting from

The SEC’s Division of Investment Management and Division of Corporation Finance published joint guidance on June 30, 2014 regarding investment advisers’ responsibilities in voting client proxies, and two exemptions from the federal proxy rules that are often relied upon by proxy advisory firms.

The staff noted that the guidance may require investment advisers and proxy