On November 4, 2022 – exactly three years after amended Rule 206(4)-1 (the Marketing Rule) was first issued in proposed form – compliance with the new rule becomes mandatory for all registered investment advisers (RIAs) and will impact virtually all CLOs. In a recent risk alert, the staff of the Securities and Exchange Commission (SEC or Commission) warned that upcoming examinations will focus on Marketing Rule compliance and urged RIAs to adapt their policies and procedures accordingly. While the industry has been given a long transition period in which to prepare for the new rule’s requirements, the broad reach of the amended rule has seemingly taken the CLO market by surprise.
To read the full New Adviser Marketing Rule - Impact on CLO Arrangers Insight, please click here.
