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SEC IM staff issues guidance update on mixed and shared funding

Keith T. Robinson (Dechert LLP, Washington, Washington D.C., USA)
Kimberley Church (Dechert LLP, Irvine, California, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 6 July 2015

50

Abstract

Purpose

The article alerts investment companies and insurers of important SEC staff interpretive guidance regarding reliance on industry-standard exemptive relief.

Design/methodology/approach

Current industry practices and the SEC staff’s guidance are summarized, followed by a brief discussion of the potential implications to insurance companies and investment companies.

Findings

The SEC staff recognizes that the current approach to mixed and shared funding may be outdated, with the result that insurance companies and investment companies may be able to reduce compliance and regulatory burdens.

Practical implications

It is still too soon to gauge industry reaction, but insurance companies and investment companies should monitor industry practices relating to mixed and shared funding to determine whether they need to obtain and comply with industry-standard exemptive relief.

Originality/value

The SEC staff clearly recognizes that insurance companies issuing variable insurance contracts, and the funds that serve as their underlying investments, may be able to reduce compliance monitoring burdens and simplify their operations.

Keywords

Acknowledgements

© 2015 Dechert LLP

Citation

Robinson, K.T. and Church, K. (2015), "SEC IM staff issues guidance update on mixed and shared funding", Journal of Investment Compliance, Vol. 16 No. 2, pp. 30-32. https://doi.org/10.1108/JOIC-04-2015-0023

Publisher

:

Emerald Group Publishing Limited

Copyright © 2015, Authors

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