ComplianceAlert

SEC No-Action Letter Provides Relief for Fund Affiliated Transactions

On October 12, 2018, the SEC’s Division of Investment Management issued a no-action letter to the Independent Directors Council (“IDC”) regarding the oversight of affiliated transactions. Under the Investment Company Act, Rules 10f-3, 17a-7, and 17e-1 are commonly referred to in the fund industry as the “affiliated transaction rules” and are each an Exemptive Rule…

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Amy Lynch on cybersecurity failures revealed in SEC case (IGNITES – Subscription Req’d)

Founder and President Amy Lynch discusses a recent SEC Enforcement action highlighting the importance of cybersecurity policies and processes that are custom-tailored to a firm’s business model, in this case an indie firm. In addition to leveling SafeGuards Rule violations, the SEC charged a firm for the first time under the 2013 Identity Theft Red…

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