The Regulatory Outlook for Funds and Advisers: Domestic and Foreign Priorities

March 16, 2015

Dechert’s Financial Services Team prepared the outline below describing recent regulatory initiatives impacting asset managers in connection with the 2015 Investment Company Institute (“ICI”) and Federal Bar Association (“FBA”) Mutual Funds and Investment Management Conference. The authors were Tom Bogle and Phil Hinkle with significant contributions from Wendy Fox and Kirsten Linder.

The Securities and Exchange Commission (“SEC”) Division of Investment Management is currently undertaking a number of significant initiatives that would apply to investment advisers and their registered investment company and other clients. This outline discusses, among other things:

• Current SEC rulemaking priorities, including enhanced data reporting, liquidity and derivatives initiatives and transition planning and stress testing initiatives;
• The recent request for comment by the Financial Stability and Oversight Council (“FSOC”) on financial stability in the asset management industry;
• Commentary from the Federal Reserve on financial stability risk in the asset management industry; and
• Our observations regarding the relative roles of the SEC and FSOC going forward.

Asset managers and their clients are closely monitoring these financial stability initiatives and the interplay between the FSOC and the SEC in the asset management space.

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