2023 Outlook: Potential Recession Magnifies Board Focus on 15(c) Season

Fund Directions
January 26, 2023

Nicole Crum was quoted in the article "2023 Outlook: Potential Recession Magnifies Board Focus on 15(c) Season," published by Fund Directions [sub. req'd] on January 26, 2023.

The article discusses the ongoing fears of a coming recession and how they have prompted boards to keep a close eye on the economy and think about what a market downturn could mean for fund oversight. Fund Directions infers that this, combined with the SEC's recent signals that it is scrutinizing fund fees, will give trustees more big-picture, non compliance-related issues to think about in 2023 than in previous years.

Nicole comments on this that the SEC's examinations of 15(c) reviews may prompt boards to re-evaluate what kinds of information they request from managers.

"It may be useful with the comments that have come out of the SEC, both formally and informally, for boards to really reflect on the information that they're getting during 15(c)," she says. "I think you need to request the right information as opposed to more information."

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