SEC Division of Investment Management staff letter: Pretzel & Stouffer

The SEC staff clarifies that aggregating orders for advisory clients does not violate section 17(d) of the Investment Company Act or section 206 of the Advisers Act if procedures prevent systematic disadvantage to any account. Investment companies must appropriately cover options and futures positions by holding sufficient assets or cash in segregated accounts to fulfill obligations. Advisers must allocate aggregated trades fairly, disclose their policies to clients, and complete trade tickets by the close of business on the trade date. Broker-dealers are required to maintain current records of brokerage orders and prepare confirmations on the day of the transaction or the following business day.

SEC published 7 documents in the last 30 days — get each new one by email the day it lands.

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON. D.C. 20549
DIVISION OF

INVESTMENT MANAGEMENT
Decemb~~,J.,..l~IM'l~"""""ii",.,;1i"'~'''''''' t'.
Ms. Christine E. Leone :;;..,t 'CA ._¿,..~..""..~=.. ' .,,~..:r':, ", ,,___.- .~ ~ - ~ "'""~

Pretzel & Stouffer
One South Wacker Drive '" ti " \t....4li'('ii.,~..' );ii;..~_, Suite 2500 Chicago, IL 60606-4673 :.iblic ¡ . .,--~- .,1J.O l"Td --I __',"":

Dear Ms. Leone:
,) '.nd.labillty 12. -, -qS ;'
~~:..,..".o""--~ii-l#l .~, :.,.~~""~~J&~li::òâ;/i~h~/¡i..1..-j.-,~

Read the rest free, and get an email when SEC publishes again

Email me when SEC publishes something newOne email per publication, same day. Sign in below to keep reading.

Lineage: In force

amendssupersedesissued underrefers toproposed or not in RegAlertarrows run from the older text to the one that changes it

Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works