The SEC’s Recent Focus on the 15(c) Process

Partners Mary Hansen, Mike Malloy and Diana McCarthy gave a presentation on the topic “The SEC’s Recent Focus on the 15(c) Process” at the Investment Company Institute’s 2015 General Membership Meeting in Washington, D.C. on May 7. The presentation included a discussion of distribution in guise, fees charged to similar clients, exemptive orders, the oversight of sub-advisers, and SEC enforcement actions (advisers and boards).