Is the U.S. SEC IM Guidance Update Initiative Becoming a Thing of the Past?

December 22, 2015

Over the past three years, the Division of Investment Management (Division) of the U.S. Securities and Exchange Commission (Commission) has provided informal guidance and interpretations regarding issues of relevance to the investment management industry, through a guidance update initiative (Initiative). As of the date of this article, the Division staff has published only four guidance updates this year, compared to the publication of 13 and 14 guidance updates during 2014 and 2013, respectively. Although this raises the question of whether the Division will continue to issue guidance updates, the investment management industry must remain mindful, and consider the potential implications, of the Division’s guidance updates.

This article provides a brief overview of the Initiative as well as a summary of the guidance updates published by the Division in 2015. The article concludes by discussing whether, in light of the significant decrease in the number of 2015 guidance updates, the Initiative may be becoming a thing of the past.

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