Investment Management Regulatory Update
A Summary of Current Investment Management Regulatory Developments

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On September 19, 2007, the SEC unanimously voted to adopt, on an interim final basis, temporary Rule 206(3)-3T under the Investment Advisers Act of 1940 (the "Advisers Act"), which provides temporary relief for certain nondiscretionary advisory accounts (including accounts that until now were operated as fee-based brokerage accounts) from the principal trading restrictions of Section 206(3) of the Advisers Act.  The SEC release containing the temporary rule (the "Temporary Rule Release") was published on September 24, 2007.  The rule took effect on September 30, 2007, and will expire on December 31, 2009.  The SEC has asked for comments on the rule by November 30, 2007.