SEC Division of Investment Management Director Dalia Blass stated that the Division is reviewing Advisors Act advertising and cash solicitation rules, Investment Company Act custody rules and multiple challenges concerning the proxy process.
In a statement at the Independent Directors Council Conference and Governing Council meeting, Director Blass described several specific issues raised in response to the Division's smaller funds outreach initiative.
Ms. Blass identified, among others, the following challenges:
- an inability to devote internal employees or hire external counsel to assess SEC proposals and determine how to achieve compliance with new requirements;
- the complex nature of the proxy process and lengthy disclosures in proxy materials;
- meeting Investment Company Act quorum requirements, including the solicitation of shareholders; and
- outdated Investment Advisers Act advertising, cash solicitation and custody rules.
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