The SEC’s New Compliance Procedure Rule for Investment Advisers

April 8, 2004

Frederick L. White

New rule 206(4)-7 of the Securities and Exchange Commission (“SEC” or “Commission”) may be the most significant rule the SEC has adopted for investment advisers, even though it is procedural rather than substantive. The rule requires SEC-registered advisers to...

The SEC's New Compliance Procedure Rule for Investment Advisers: When Procedure Becomes Substance