US welcomes pay-to-play no-action letter

Author: | Published: 18 Oct 2011
Investment advisers have welcomed the Securities & Exchange Commission (SEC) no-action letter on pay-to-play requirements to keep records of all government entities that have invested in a covered investment pool to which they have advised.

"This was greatly longed for," one attorney said.

The Government Plan Recordkeeping Rule came into force on September 13, just a day after the SEC issued its no-action letter in response to an Investment Company Institute (ICI) request to issue an alternative set of recordkeeping obligations.

"When government entities invest in a mutual fund advised by an adviser subject to the SEC's rule, the adviser has no direct relationship with the mutual fund's clients and therefore would not know who those clients are or whether they are a government [entity]," said Tamara Salmon, senior associate counsel at the...

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