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How much (and how conflicted) is that portfolio manager in the window? Implications of the SEC proposed rule on enhanced portfolio management disclosure for registered investment companies

James A. Hartmann (Director, Risk Management & Regulatory Compliance, Ernst & Young LLP, New York, USA; james.hartmann@ey.com)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 1 July 2004

Abstract

There has been tremendous focus by the U.S. Securities and Exchange Commission (“SEC”) and by other parties, such as the New York Attorney General, on investment advisory fees levied by mutual funds as well as conflicts of interest between portfolio managers and their various types of clients. Sometimes these debates have ended up in Congress where the implied threat to the SEC was “if you don’t act we will.” And some of the congressional proposals, if enacted, would have created far‐reaching consequences for both investors and investment companies by proscribing certain conflicts. The SEC, on the other hand, has used sunlight principally as its preferred antiseptic. Increased disclosure requirements over a variety of activities has been the norm in the its recently adopted rules and regulations. The Commission has proposed amendments to Forms N1‐A, N‐2, N‐3 and N‐CSR calling for enhanced disclosure regarding the three C’s: compensation, composition of the management team, and conflicts of interest.

Keywords

Citation

Hartmann, J.A. (2004), "How much (and how conflicted) is that portfolio manager in the window? Implications of the SEC proposed rule on enhanced portfolio management disclosure for registered investment companies", Journal of Investment Compliance, Vol. 5 No. 3, pp. 55-58. https://doi.org/10.1108/15285810410636479

Publisher

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Emerald Group Publishing Limited

Copyright © 2004, Emerald Group Publishing Limited