SEC Reminds Fund Advisors to Review – Gifts and Entertainment Policies
The SEC recently issued a Guidance Update reminding mutual fund investment advisors (Advisors) that the receipt of gifts or entertainment by fund advisory personnel from persons doing business or hoping to do business with the fund may violate section 17(e)(1) of the 1940 Act.
While most Advisors’ Codes of Ethics address this practice, the SEC suggests that it should also be addressed by funds’ compliance policies and procedures.
To view the SEC’s Guidance Update, click on the link below:
What You Should Do:
Review your firm’s Code of Ethics to ensure that the receipt of gifts and entertainment from persons doing business or seeking to do business with the fund is prohibited or only allowed through a pre-clearance procedure;
Review your firm’s current policies and procedures regarding gifts and entertainment;
If necessary, develop or enhance your firm’s policies and procedures to fully address this issue.
How Oyster Can Help:
Oyster Consulting can review your firm’s Code of Ethics and Policies and Procedures, not only with regard to Gifts and Entertainment, but also to assess areas where these documents may need further enhancement to remain ahead of the regulatory curve. Contact Oyster Consulting for more information on Compliance Program reviews. One of our Associates will be happy to help you.
Oyster Consulting, LLC
4128 Innslake Dr
Glen Allen, VA 23060