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Comments on Investment Company Act Cross-Trading Rule 17a-7

The IAA called on the SEC to modernize the Investment Company Act cross-trading rule, recommending that the SEC reverse a new definition of “readily available market quotations,” amend the rule to codify relief related to board oversight, and recognize the protections afforded to fund shareholders by the Advisers Act fiduciary duty.

April 11, 2021

Keywords: Cross Trading, SEC, Valuation

Categories & Topics: Brokerage & Trading, Business Ops/HR, Registered Funds

Comments on SEC Fair Value Proposal

The IAA generally supported the proposal but recommended more flexibility regarding the reporting requirements, making the definition of “readily available market quotation” reflect current valuation practices, and flexibility for a fund board to assign the fair value determination to the fund’s primary adviser or sub-adviser.

July 21, 2020

Keywords: Fair Value, Investment Company Act, Valuation

Categories & Topics: Compliance, Registered Funds, Valuation

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