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Division of Investment Management: Information and Guidance Updates

June 2, 2015

These archived sections consist of prior staff information or guidance updates issued by the Division of Investment Management:

Information Updates Archive

INFO-2023-02 – Updates to Form ADV Frequently Asked Questions
INFO-2023-01 – Expedited Review of Applications & Automatic Withdrawal

INFO-2019-01 – Website Updates to Investment Company Forms

INFO-2018-02 – Statement Regarding Staff Proxy Advisory Letters
INFO-2018-01 – Updates to Custody Rule Frequently Asked Questions

INFO-2017-07 – Applicability of Staff Accounting Bulletin No. 118 to Investment Companies Impacted by the Tax Cuts and Jobs Act
INFO-2017-06 – Information Update for Advisers Filing Certain Form ADV Amendments
INFO-2017-05 – Updates to Mid-Sized Adviser Frequently Asked Questions
INFO-2017-04 – Updates to Form ADV Frequently Asked Questions
INFO-2017-03 – Information Update for Advisers Relying on the Unibanco No-Action Letters
INFO-2017-02 – Letters to Support Tax Claims in Foreign Jurisdictions
INFO-2017-01 – Updates to Form PF Frequently Asked Questions

INFO-2014-06 – Updates to Form PF Frequently Asked Questions
INFO-2014-05 – Staff Legal Bulletin: Proxy Voting Responsibilities of Investment Advisers
INFO-2014-04 – Updates to Frequently Asked Questions About Form 13F
INFO-2014-03 – Exemptive Applications Review: Comparison Documents
INFO-2014-02 – Division of Investment Management Year in Review
INFO-2014-01 - Updates to Form PF Frequently Asked Questions

INFO-2013-11 - Updates to FAQs About Form 13F
INFO-2013-10 - Updates to Form PF Frequently Asked Questions
INFO-2013-09 - Exchange-Traded Funds Using Affiliated Index Providers
INFO-2013-08 - Updates to FAQs About Form 13F
INFO-2013-07 - Division Extends the Benefits Under Rule 486(b) to Additional Closed End Funds
INFO-2013-06 - Division Launches Money Market Fund Web Page
INFO-2013-05 - Money Market Fund Identifier Numbers Made Available to Public
INFO-2013-04 - Technical Improvements Implemented to Form 13F
INFO-2013-03 - Updates to FAQs About Form 13F
INFO-2013-02 - Improvements to Form 13F
INFO-2013-01 - The Division of Investment Management Posts Office Contact Information

Guidance Updates Archive

2017-03 - Holding Companies and the Application of Rule 3a-2 under the Investment Company Act
2017-02 - Robo-Advisers
2017-01 - Inadvertent Custody: Advisory Contract Versus Custodial Contract Authority

2016-06 - Mutual Fund Fee Structures; see also Frequently Asked Questions on IM Guidance Update 2016-06 (Mutual Fund Fee Structures)
2016-05 - Staff Guidance Concerning Investment Adviser Reliance on Predecessor Registrations
2016-04 - Business Continuity Planning for Registered Investment Companies
2016-03 - Fast Act Changes Affecting Investment Advisers to Small Business Investment Companies
2016-02 - Fund Disclosure Reflecting Risks Related to Current Market Conditions
2016-01 - Mutual Fund Distribution and Sub-Accounting Fees

2015-04 - Employees' Securities Companies and Escheatment
2015-03 - Code of Ethics Guidance for Investment Advisers
2015-02 - Cybersecurity Guidance
2015-01 - Guidance Regarding Acceptance of Gifts or Entertainment by Fund Advisory Personnel

2014-13 - Guidance Regarding Key Employee Trusts Under the Family Office Rule
2014-12 - Guidance Regarding Business Development Companies-Transactions with Certain Second-Tier Affiliates
2014-11 - Guidance Regarding Investment Company Consolidation
2014-10 - Guidance Regarding Mixed and Shared Funding Orders
2014-09 - Business Development Companies with Wholly-Owned SBIC Subsidiaries-Asset Coverage Requirements
2014-08 - Guidance Regarding Mutual Fund Enhanced Disclosure
2014-07 - Private Funds and the Application of the Custody Rule to Special Purpose Vehicles and Escrows
2014-06 - Series Investment Companies: Affiliated Transactions
2014-05 - Deregistration of Investment Companies: Applications On Form N-8F
2014-04 - Guidance on the Testimonial Rule and Social Media
2014-03 - Multi-Manager Funds – Aggregate Advisory Fee Rate
2014-02 - Unbundling of Proxy Proposals-Investment Company Charter Amendments
2014-01 - Risk Management in Changing Fixed Income Market Conditions

Issues of Interest - Investment Advisers Act

Investment Advisers Registered with the Commodity Futures Trading Commission ("CFTC") that Advise Private Funds (November 15, 2012)
Advisory Contracts - Consent (June 15, 2012)
Advisory Contracts - Transition for Newly Registered and Registering Advisers (March 30, 2012)
Persons Who Provide Advice Solely Regarding Matters Not Concerning Securities (March 27, 2012)

Issues of Interest - Investment Company Act

After-Tax Return (February 22, 2013)
Joint Transactions — Portfolio Holdings of Companies Electing Status as Business Development Companies ("BDCs") (November 27, 2012)
Affiliated Funds of Funds — Section 12(d)(1) of the Investment Company Act (October 19, 2012)
Advisory Contracts — Combined Investment Advisory and Service Fees (October 5, 2012)
Funds Using Tender Option Bond (TOB) Financings (March 29, 2012)
Business Development Companies — Auditor Verification of Securities Owned (March 12, 2012)
Rule 18f-3 under the Investment Company Act — Removal of a Class (September 2, 2010)
Rules 436 and 482 under the Securities Act (August 10, 2010)

Last Reviewed or Updated: Feb. 1, 2026