ACA Panel Reviews Affiliated Transaction Rules (Part One of Two)

Investment advisers that advise alternative mutual funds or other registered funds are subject to the overlapping – but distinct – regulatory regimes established by the Investment Company Act of 1940 (Investment Company Act) and the Investment Advisers Act of 1940. A recent ACA Compliance Group (ACA) program – featuring Erik Olsen and Vicki Hulick, ACA director and senior principal consultant, respectively – offered a detailed overview of the provisions of the Investment Company Act and related rules that govern trading by registered investment companies. This article, the first in a two-part series, covers the portions of the program that addressed transactions with affiliates. The second article will address the aggregation of publicly traded securities; best execution; soft dollars; portfolio-holding liquidity; and gifts and entertainment. See our three-part series on the simultaneous management of hedge funds and alternative mutual funds following the same strategy: “Investment Allocation Conflicts” (Apr. 2, 2015); “Operational Conflicts” (Apr. 9, 2015); and “How to Mitigate Conflicts” (Apr. 16, 2015).

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