SEC Division of IM Guidance Update: Series Investment Companies and Affiliated Transactions

The staff of the SEC's Division of Investment Management ("IM") issued guidance to remind mutual funds that are "series companies" that their compliance policies and procedures must be designed reasonably to prevent violations of the federal securities laws as they apply to each series; i.e., that each "series company" should be treated as a separate legal entity. In particular, a mutual fund should review its compliance policies and procedures for the appropriate identification of "affiliated persons" with respect to each series of the mutual fund for purposes of transactions that may be prohibited under the Investment Company Act of 1940.

See: SEC IM Guidance Update.