Open Call: Outsourcing by Investment Advisers SEC Proposed New Rule 206(4)-11, and Amendments to Rule 204-2 and Form ADV

On October 26, 2022, the Securities and Exchange Commission (SEC) proposed new rule 206(4)-11 and rule amendments under the Advisers Act that prohibit SEC-registered investment advisers from outsourcing certain services or functions to service providers and third-party recordkeepers without meeting minimum due diligence and monitoring requirements.

If adopted in its current form, the requirements would have a significant impact on the due diligence and monitoring obligations of SEC-registered advisers on a broad range of functions including outsourced or supplementary trading arrangements.


Jeff Estella


Estella LLC

David Lourie

Vice President & Senior Counsel

Regulatory Affairs

Managed Funds Association

Open Call Index

Opening Remarks: 00:00

Q#1: Current State of Outsourcing and Why Now: 04:20

Q#2: How the Proposal is different than current regime: 10:05

Q#3: Top Compliance Challenges: 16:50

Q#4: Next Steps: 23:00