ACA Panel Reviews Rules Related to Aggregation of Publicly Traded Securities, Best Execution, Soft Dollars, Portfolio Holding Liquidity and Gifts (Part Two of Two)

A recent ACA Compliance Group (ACA) program provided a detailed overview of the provisions of the Investment Company Act of 1940 and related rules that govern trading by registered investment companies. The program featured Erik Olsen and Vicki Hulick, ACA director and senior principal consultant, respectively. This article, the second in a two-part series, covers the portions of the program that addressed the aggregation of publicly traded securities; best execution; soft dollars; portfolio holding liquidity; and gifts and entertainment. The first article addressed transactions with affiliates. For additional commentary from ACA, see “What Robo-Advisers Can Expect From SEC Examinations” (Jun. 21, 2018); and “Developing a 2018 Compliance Budget: How Investment Advisers Can Make the Most of Limited Resources” (Dec. 21, 2017).

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