Adviser Relief From Pay-To-Play Recordkeeping

Law360, New York (October 6, 2011, 5:39 PM EDT) -- The staff of the Securities and Exchange Commission has issued a no-action letter (Investment Company Institute No-Action Letter, Sept. 12, 2011) providing partial relief from the recordkeeping obligations of investment advisers, including certain fund managers, under Rule 204-2(a)(18) of the Investment Advisers Act of 1940  (the “Recordkeeping Rule”) with respect to the SEC’s “Pay-to-Play Rule” (Rule 206(4)-5). Investment advisers to registered investment companies were required to be in compliance with the Recordkeeping and Pay-to-Play Rules by Sept. 13, 2011.

The Pay-to-Play Rule prohibits an investment adviser...
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