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.
Presenters:
Jeff Estella
Founder
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