This is a transformational time for the US asset management industry. The SEC is requesting complex information that they have never before requested in a 30-day filing format. We're about a year away from the bulk of the requirements of SEC modernization and liquidity rules coming into play. While asset managers have been hard at work on their implementation, they still await some key guidance from the SEC and other industry groups. For those still working on their implementation, we have a few key steps we recommended. The first is to establish working groups, keying in on data requirements and assigning data ownership. The second is to create an action plan on how that data then gets transmitted to the SEC.
The positions expressed in this material are those of the author as of June 23, 2017, and may or may not be consistent with the views of Brown Brothers Harriman & Co. and its subsidiaries and affiliates (“BBH”), and are intended for informational purposes only. Furthermore, these positions are not intended to predict or guarantee the future performance of any currencies or markets. This material should not be construed as research or as investment, legal or tax advice, nor should it be considered information sufficient upon which to base an investment decision.