SEC Staff Issues Relief from Pay-to-Play Recordkeeping Requirements for Investment Advisers to Registered Investment Companies

September 23, 2011
The Staff of the Securities and Exchange Commission issued a no-action letter that provides relief from the “pay-to-play” recordkeeping requirements for investment advisers to registered investment companies. This update examines the challenges to comply with the recordkeeping requirements as adopted and discusses the “alternative” set of records that will be deemed to satisfy the recordkeeping requirements.