Key takeaways

• In a recent speech, Securities and Exchange Commission (“SEC”) Chair Mary Jo White outlined three initiatives aimed at the investment management industry that appear to be in response to a recent decision by the Financial Stability Oversight Council to refrain from designating individual asset managers as systemically important and reflect the SEC’s increasing focus on the asset management industry.
• The initiatives include: (i) expanded data reporting for registered investment companies and investment advisers, including with respect to separately managed accounts (ii) enhanced controls on risks related to portfolio composition and (iii) improved “transition planning” (analogous to the “living will” requirements impacting some bank holding companies) and stress testing.
• The rules that will implement these initiatives will likely be proposed for public comment in the coming year.