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Public Input on Climate Change Disclosures

The IAA weighed in on the ESG corporate disclosure debate with a letter to the SEC stressing the importance of facilitating sustainable investing by advisers on behalf of their clients and calling for consistent, comparable, and reliable baseline corporate issuer disclosures of climate- and ESG-related risks.

June 11, 2021

Tags: Climate, Disclosure, ESG, SEC

Engaging on Non-DVP Custodial Practices

The Investment Adviser Association (“IAA”), the Asset Management Group (“AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”), and the Loan Syndications and Trading Association (“LSTA”) (together, the “Associations”) appreciate the opportunity to respond to the Division of Investment Management Staff’s request for engagement on the application of the Custody Rule to non-DVP trading, as set forth in a letter from the Staff to the IAA.

May 13, 2021

Tags: Custody (non-DVP), SEC

Comments on Division of Investment Management Staff Statement on Investment Company Cross Trading Rule 17a-7

The Investment Adviser Association (“IAA”) appreciates the opportunity to comment on the Division of Investment Management’s “Staff Statement on Investment Company Cross Trading.” Many IAA members act as investment advisers or sub-advisers to registered investment companies (“funds”). Today, funds may engage in securities transactions in both equity and fixed income securities with certain of their affiliates (“cross trades”), allowing funds and their shareholders to benefit from cost savings and efficiencies they would not obtain in the open market. The economic benefits from reducing transaction costs accrue directly to funds and shareholders – not to investment advisers. These cross trades must be effected in accordance with Rule 17a-7 (the “Cross Trading Rule”) under the Investment Company Act of 1940 (“Investment Company Act”), which contains several conditions for cross trades that are designed to protect fund investors from conflicts of interest and other risks. In the absence of arms-length open-market negotiation that would otherwise determine execution price, a key goal of Rule 17a-7 is ensuring that pricing is fair to all funds and accounts involved. Among the conditions under the Cross Trading Rule are that the transactions must be in securities for which “market quotations are readily available,” and must be effected at the “independent current market price” of the security.

April 11, 2021

Tags: Cross Trading, SEC

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