The Securities and Exchange Commission on June 15, 2022 requested comments related to information providers (such as index providers, model portfolio providers and pricing services) whose activities the SEC believes may bring them within the definition of “investment adviser” under the Investment Advisers Act of 1940 (Request). The Request follows comments by the Director of the Division of Investment Management in a recent speech, in which he asserted that the traditional role of investment advisers has “splintered” among various service providers (including “Information Providers” or “Providers,” as defined below). The Request focuses on whether such information providers are acting as investment advisers in ways that might warrant regulation under the Advisers Act and the Investment Company Act of 1940.
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