Securities Law Updates | New Releases/No Action Letters
October 21, 2009
SEC Grants Omgeo’s Request for Relief under Investment Advisers Act of 1940
Investment Advisers Act of 1940 — Rules 204-2(a), (b) and (g) Omgeo LLC
Ref. No. 2009716179 , 8/14/2009
In this no-action letter, the Division of Investment Management (“Division”) of the Securities and Exchange Commission (“SEC”) held that it will not recommend enforcement action to the SEC under Rules 204-2(a)(7), 204-2(b)(3) and 204-2(g) under the Investment Advisers Act of 1940 (the “Advisers Act”) against an investment adviser registered under the Advisers Act (“Adviser”) that subscribes to a Recordkeeping Service (as defined below) provided by Omgeo LLC (“Omgeo”) if trade confirmations are made and kept in the manner stated in its request letter for relief.
By way of background, Omgeo’s TradeSuite service electronically transmits trade confirmations (“TradeSuite confirmations”) to Advisers on…
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