SEC Division of Investment Management Frequently Asked Questions
Summary
The SEC's Division of Investment Management has published an updated list of Frequently Asked Questions (FAQs) addressing various topics relevant to investment advisers and companies. These FAQs provide staff interpretations and do not create new legal obligations.
What changed
The Securities and Exchange Commission's Division of Investment Management has released an updated compilation of Frequently Asked Questions (FAQs) on its website. This document, dated November 8, 2024, consolidates staff responses to common inquiries concerning a wide range of topics, including auditor independence, business development companies, custody rules, family offices, financial conflicts, various SEC forms (13F, ADV, CRS, N-MFP, PF), fund of funds arrangements, liquidity risk management, and marketing compliance. These FAQs represent the views of SEC staff and are intended to provide guidance, not to establish new rules or regulations.
While these FAQs are non-binding and do not create new legal obligations or alter existing law, they offer important clarifications and interpretations that regulated entities, such as investment advisers, fund managers, and public companies, should review. Compliance officers should consult these FAQs to ensure their practices align with SEC staff expectations regarding disclosure, reporting, and operational requirements. The document notes that staff may update this information periodically, suggesting ongoing review is advisable.
What to do next
- Review updated SEC Division of Investment Management FAQs for relevant topics
- Assess current compliance practices against staff interpretations provided in the FAQs
- Consult legal counsel if any FAQ responses indicate potential areas of non-compliance or require policy adjustments
Source document (simplified)
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Division of Investment Management: Frequently Asked Questions
Nov. 8, 2024 This is a non-exhaustive listing of responses to frequently asked questions on various topics that have been prepared by staff in the Division of Investment Management. Staff may update this information from time to time to include responses to additional questions. These responses represent the views of the staff and are not rules, regulations, or statements of the Commission. The Commission has neither approved nor disapproved the answers to these FAQs, which like all staff statements have no legal force or effect, do not alter or amend applicable law, and create no new or additional obligations.
| Title | Date (Last Updated) | Topic |
| --- | --- | --- |
| Auditor Independence | June 27, 2019 | Accounting and Auditing |
| Business Development Companies and Section 61(a) of the Investment Company Act of 1940 | Oct. 18, 2019 | |
| Coronavirus (COVID-19) Response | July 21, 2022 | Emergencies |
| Custody Rule | Oct. 10, 2017 | Accounting and Auditing |
| Family Office Rule | March 23, 2018 | Accounting and Auditing |
| Financial Conflicts Related to Investment Adviser Compensation (Disclosure) | Oct. 18, 2019 | Registration and Disclosure |
| Form 13F | May 25, 2023 | Investment Advisers |
| Form ADV and IARD | Oct. 26, 2023 | Investment Advisers |
| Form CRS | Dec. 8, 2023 | Registration and Disclosure |
| Form N-MFP | Jan. 25, 2011 | Money Market Funds |
| Form N-MFP and Rule 30b1-7 | July 29, 2011 | Money Market Funds |
| Form PF | Apr. 4, 2025 | Accounting and Auditing |
| Fund of Funds Arrangements | March 5, 2026 | Filing Fees |
| Fund of Funds Expenses (Disclosure) | May 23, 2007 | Accounting and Auditing |
| Investment Company Liquidity Risk Management Programs | April 10, 2019 | Portfolio Management |
| Investment Company Names (Rule 35d-1) | Dec. 4, 2001 | Portfolio Management |
| Investment Company Reporting Modernization | April 21, 2021 | Accounting and Auditing |
| Marketing Compliance | Jan. 15, 2026 | Advertising/Performance/Social Media |
| Mid-Sized Advisers | June 30, 2017 | Investment Advisers |
| Money Market Fund Reforms (2014 rulemaking) | Feb. 17, 2021 | Money Market Funds |
| Money Market Fund Reforms (2010 - Rule 2a-7) | Aug. 7, 2012 | Money Market Funds |
| Mutual Fund After-Tax Return Requirements | Jan. 14, 2002 | Accounting and Auditing |
| Mutual Fund Customer Identification Program Rule | Aug. 11, 2003 | Anti-Money Laundering |
| Mutual Fund Fee Structures (IM Guidance Update 2016-06) | Feb. 15, 2017 | Distribution Arrangements |
| Names Rule (2025–26 FAQs) | Feb. 18, 2026 | Investment Companies |
| Names Rule (Withdrawn 2001 FAQs) | Jan. 8, 2025 | Investment Companies |
| Pay-to-Play Rule | Aug. 18, 2017 | Investment Advisers |
| Proxy Disclosure Enhancements Transition for Registered Investment Companies | Jan. 19, 2010 | Compliance - Investment Companies |
| Proxy Voting Responsibilities of Investment Advisers | June 30, 2014 | Investment Advisers |
| Regulation S-P | Jan. 23, 2003 | Privacy/Identity Theft |
| Reserve Fund | Oct. 1, 2008 | Money Market Funds |
| Rule 35d-1 (Investment Company Names) | Sept. 29, 2011 | Transaction Fees |
| Standards of Conduct for Broker-Dealers and Investment Advisers (Account Recommendations for Retail Investors) | March 30, 2022 | Regulation Best Interest |
| Standards of Conduct for Broker-Dealers and Investment Advisers (Care Obligations) | April 30. 2023 | Regulation Best Interest |
| Standards of Conduct for Broker-Dealers and Investment Advisers (Conflicts of Interest) | Aug. 3, 2022 | Regulation Best Interest |
| Tailored Shareholder Reports | Jan. 26, 2024 | |
| Valuation | March 18, 2021 | Accounting and Auditing |
| Valuation Guidance | Oct. 5, 2022 | Accounting and Auditing |
| Volcker Rule | March 4, 2016 | |
Last Reviewed or Updated: March 6, 2026
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