07/13/2022
Carrie F Rinehart-Bekker: This is the fourth installment of our BCCP Summer Compliance Series.
If you are a discretionary manager and if all of your clients get generally the same portfolio -- with the same securities in approximately the same measure -- you may be running a de facto mutual fund (in the eyes of regulators). In order to prevent being considered an investment company, you need to take a few steps.
This is the fourth installment of our BCCP Summer Compliance Series. When we think of investment advisor regulation, advisors are familiar with the typical SEC and/or state rules they must follow. However, there are a few rules in other Acts that apply to all market participants, regardless of regul...