December 19, 2003

Transcript from “The New Governance

This webcast – featuring in-house practioners Peggy Foran of Pfizer, Jim Gunderson of Schlumberger, Susan Wolf of Schering-Plough, and Tina Van Dam of Dow Chemical was chock full of practice pointers. If you are a member of, check out the transcript.

Note that today is the holiday party at the SEC – so many staffers will be understandably busy during the afternoon.

SEC Issues Final Rules on Investment Companies/Advisors Compliance Programs

On Wednesday, the SEC posted its final rules on compliance programs for investment companies and investment advisers. The adopting release requests comments on whether there are other measures or refinements that would further enhance the independence and effectiveness of chief compliance officers under the rule, and comments on the definition of “material compliance matters” that must be reported to fund boards by chief compliance officers.

The release provides an effective date of Feb. 5 – and a compliance date of Oct 5, 2004. It specifies the deadlines for the first annual review by funds and advisers and the first annual report to the board by the chief compliance officer of a fund. The release also states that the transition period does not reduce the immediacy of the need for all funds to undertake a review of their policies and procedures.