Investment company policies and procedures

Therefore, the chief compliance officer must oversee the insurance company’s compliance program with respect to the separate accounts, including the processing of new account applications, premium payments, and exchanges. See supra note However, a firm that does not currently have a person qualified to serve as chief compliance officer will incur costs associated with training someone in the firm. Third, we are requiring that the chief compliance officer meet in executive session with the independent directors at least once each year, without anyone else such as fund management or interested directors present. The fund board including a majority of independent directors must approve the designation of the chief compliance officer, and must approve her compensation or any changes in her compensation. In and , the Division of Investment Management issued interpretive letters elaborating on funds’ obligations under sections 2 a 41 of the Investment Company Act and rule 22c-1 [17 CFR See infra note

Securities and Exchange Commission

Summary: The Securities and Exchange Commission is adopting rule and form amendments under the Securities Act ofthe Securities Exchange Act ofand the Investment Company Act of to require registered management investment companies to provide disclosure about how they vote proxies relating to portfolio securities they hold. These amendments require registered management investment companj to disclose the policies and procedures that they use to determine how to vote proxies relating to portfolio securities. The amendments also require registered management investment companies to file with the Commission and to make available to shareholders the specific proxy votes that they cast in shareholder meetings of issuers of portfolio securities. Comment Date : Comments regarding the «collection of information» requirements, within the meaning of the Paperwork Reduction Act ofof Form N-PX should be received by March 14, Addresses: To help us process and review your comments more efficiently, comments should be sent by hard copy or electronic mail, but not by both commpany. Comments sent by hard copy should be submitted in triplicate to Jonathan G. Comments also may be submitted electronically at the following E-mail address: rule-comments sec.

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The Board of Governors will approve Specific Investment Policies for each fund investment company policies and procedures grouping of funds, which in the determination of the Board of Governors, requires a separate investment policy. Description of Investment Policy 1. All equities should normally be dividend paying. Investment in derivative instruments may be used for hedging purposes to facilitate ingestment management of risk or to facilitate an economical substitution for a direct investment.

Under no circumstances will derivatives procdures used to create leveraging of the portfolios. Asset-backed commercial paper is considered a prohibited investment. Within this overall objective the portfolios should seek to earn total returns exceeding the rate of inflation over the long run if possible. Over the short-term and, in the intermediate term, provide SJU with income generated by the fixed-income portion of the portfolios and dividend paying companies. The portfolio performance measures are: 1.

Cash flow return of the total portfolio prior to fees; 2. Portfolio growth target; and 3. All reporting for that fiscal inveestment will measure portfolio performance against the established target return. The primary objective is income generation with a secondary focus on growth. The equity portion of the portfolios should enhance returns yet maintain purchasing power. Exceptions to the rating requirements of bonds and preferred shares may be approved by the University subject to written request by the Investment Manager.

A balanced portfolio across sectors to hedge against market volatility shall be a priority. The Investment Manager shall maintain a stop loss protocol and will be required to communicate to the University representatives how the provision is being investment company policies and procedures to protect cimpany assets of the portfolio. Prudent Investor Standard of Care: Nad standard of care that shall apply to the Ajd of Funds of the University shall be care, diligence invwstment judgment that a prudent investor would exercise in making investments.

When this occurs, the Investment Manager will undertake to realign the portfolios within a reasonable period of time on a best efforts basis in accordance with this Investment Portfolio Statement. Related documents.

What Is a Management Investment Company?

17 CFR Parts 239, 249, 270, and 274

As discussed above, the new rules would require funds and investment advisers to adopt and implement written policies and procedures designed to prevent violations of the federal securities laws, and review those policies and procedures at least annually. All comment letters should refer to File No. Most of the firms without any review mechanism in place are small. Accordingly, our estimate of the annual aggregate burden of collection for the amended rule remainshours. Open an Ariel Mutual Fund Account. The chief compliance officer should be familiar with each service provider’s operations and understand those aspects of their operations that expose the fund to compliance risks. Similarly, the board’s review of the chief compliance officer’s annual investment company policies and procedures should focus on ensuring that the compliance programs of the fund and its service providers are reasonably designed and functioning effectively. Private Sector Initiatives In the Proposing Release, we requested that commenters consider four additional approaches that we might take to require the private sector to assume greater responsibility for compliance with the federal securities laws.