Investment Management APRIL 2004

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1 Investment Management APRIL 2004 SEC Proposes New Disclosure on Portfolio Managers The Securities and Exchange Commission ( SEC ) recently proposed new disclosure requirements related to portfolio managers of registered investment companies. The proposals would require funds to disclose: (1) the individual team members of portfolio management teams; (2) the other accounts managed by fund managers and the potential conflicts of interest involved in managing those other accounts; (3) the structure of portfolio manager compensation; and (4) the ownership interests of portfolio managers in the funds and other accounts they manage, as well as other accounts managed by the same investment adviser. 1 These proposals are designed to increase transparency regarding the identity of portfolio managers, their incentives in managing a fund and the potential conflicts of interest they may encounter in managing multiple investment accounts. The proposals attempt to address the issues involved in the side-by-side management of registered investment companies and unregistered hedge funds, as well as the conflicts and incentives involved in managing other accounts with performance-based fees. Comments on these proposals must be submitted to the SEC on or before May 21, PORTFOLIO MANAGEMENT TEAM MEMBERS The proposed amendments would require funds to state in their prospectuses the name, title, length of service, and business experience of each member of a portfolio management team. Under current requirements, investment companies managed by a committee or team are not required to give information about the individuals comprising the group, but are simply required to state that the fund is managed by a group. 2 The proposals also would require funds to include a brief description of the role of each member on the portfolio management team, such as lead member. In the release proposing these disclosure amendments ( Proposing Release ), the SEC explained that some observers have argued that the use of portfolio management teams has provided funds with a way to avoid disclosing who is responsible for managing a fund and how long (or briefly) a manager has held that position. 3 Although not expressly discussed in the Proposing Release, the portfolio management team concept could be used as a means to manipulate the portability of a manager s prior performance. For example, when individual portfolio management team members and 1 The proposals would amend Forms N-1A, N-2 and N-3, the registration forms used by management investment companies to register their shares under the Investment Company Act of 1940 ( 1940 Act ) and to offer their securities under the Securities Act of With respect to closed-end investment companies, the proposals would amend Form N-CSR under the 1940 Act and the Securities Exchange Act of 1934, the form on which investment companies file shareholder reports with the SEC. The SEC proposed that closed-end funds provide the disclosures in their annual reports on Form N-CSR since they are not required to update their registration statements annually. 2 Form N-3, the registration form used by insurance company managed separate accounts that issue variable annuity contracts, does not currently require disclosure about portfolio managers. The proposed amendments would require these separate accounts to make the same disclosures relating to portfolio managers required by the other investment company forms, including disclosure about the individual members of a portfolio management team. 3 Investment Company Act Release No (Mar. 11, 2004). Kirkpatrick & Lockhart LLP

2 their roles are not identified, a portfolio manager who moves to a different fund group could claim that he was the team member primarily responsible for managing another similarly managed fund at the previous adviser who employed him, and use that fund s prior performance to his advantage. 4 The SEC is seeking comment on whether all members of a portfolio management team should be identified or only certain members, such as the lead member, and whether the disclosures should be required of all team members. OTHER ACCOUNTS MANAGED BY THE FUND MANAGER AND POTENTIAL CONFLICTS OF INTEREST Under the proposed amendments, a registered investment company would be required to provide information in its Statement of Additional Information ( SAI ) regarding other accounts for which the fund s portfolio manager has day-to-day management duties. The disclosure would include the total number of other accounts, the total assets in the accounts and the number of accounts and total assets for which the adviser receives a performancebased fee. Accounts include registered and unregistered investment companies, other pooled investment vehicles and other accounts. In addition, if a fund s portfolio manager is part of a team that manages another account and that team is jointly and primarily responsible for the day-to-day management of that account, the fund would be required to include the required disclosures regarding that account. 5 The proposals also would require disclosure of the potential conflicts of interest involved in managing a fund and these other accounts. The Proposing Release states that this disclosure would include, for example, conflicts between the fund s investment strategy and the investment strategy of the other accounts managed by the fund s portfolio manager and conflicts in allocation of investment opportunities between the fund and the other accounts. Funds would also be required to disclose the policies and procedures they or their advisers use to address such conflicts. Alternatively, funds would be permitted to include a copy of these policies and procedures. 6 The SEC is seeking comment specifically on whether it should prohibit portfolio managers of registered funds from managing certain types of accounts. It is not clear from the Proposing Release whether the SEC believes that requiring that such conflicts be disclosed could alleviate the conflicts involved in side-by-side management. PORTFOLIO MANAGER COMPENSATION STRUCTURE Under the proposed amendments, funds also would be required to disclose in their SAIs the structure of, and the method and criteria used to determine, the compensation of their portfolio managers. The disclosure would be required to include information about the compensation received by a fund s portfolio manager with respect to management of the fund as well as any other accounts managed by the portfolio manager. According to the Proposing Release, compensation would include, without limitation, salary, bonus, deferred compensation and pension and retirement plans and arrangements and any non-cash compensation. Funds would not need to disclose the actual amount of the compensation, although the SEC is seeking comment on whether this information should be disclosed. Critics of the proposal have argued that fund managers who do not want information regarding their compensation shared with the public will choose to manage only unregistered investment vehicles, particularly if the proposal is revised to require disclosure of the actual dollar amount of a manager s compensation. 4 See, e.g., Bramwell Growth Fund, SEC No-Act. (Aug. 7, 1996) (permitting use of portfolio manager s prior performance information at another firm because she had primary responsibility for managing the old fund and played the same role in managing the new fund). 5 The Proposing Release does not clarify what it means to be jointly and primarily responsible. However, it appears that a fund would not be required to include the disclosures relating to the other account, for example, if that account is managed by a team that designates a lead member and the fund s portfolio manager is not the lead member of the team that manages the other account. 6 These types of procedures are already required by Rule 38a-1 under the 1940 Act. Kirkpatrick & Lockhart LLP 2

3 The description of compensation would be required to disclose any differences in the compensation received for managing the fund versus other accounts, including, for example, whether the manager receives a portion of a performance-based fee on some accounts other than the fund. According to the Proposing Release, this information would assist investors in assessing the manager s incentives. For each type of compensation, funds would be required to describe the criteria on which the compensation is based, e.g., whether compensation is based on before- or after-tax performance and whether compensation is based on the value of assets in the fund s portfolio. SECURITIES OWNERSHIP OF PORTFOLIO MANAGERS The proposed disclosure amendments would require a fund to disclose in a tabular format in its SAI the dollar range of securities owned beneficially or of record by the fund s portfolio manager in the fund and in other accounts managed by an investment adviser of the fund, or by any person directly or indirectly controlling, controlled by, or under common control with an investment adviser or principal underwriter of the fund. The dollar ranges would mirror the current requirements for disclosure of fund shares owned by the fund s directors. The disclosure would apply to the portfolio manager and his immediate family members; immediate family members is defined as a person s spouse, child residing in the person s household (including step and adoptive children) and any dependent of the person, as defined in section 152 of the Internal Revenue Code. According to the Proposing Release, this would assist investors in assessing the potential conflicts of interest between their interests and the interests of other clients or investment accounts in which the manager holds an interest. Among other issues, the SEC is seeking comment on: (1) whether the groups of accounts covered by the proposal are too broad or too narrow; (2) whether the actual value (as opposed to the dollar range) of securities owned by the portfolio manager is more appropriate; and (3) whether a fund should be required to disclose the percentage of a portfolio manager s net worth that is invested in securities of the fund or other accounts. As noted above, critics of the proposal have argued that fund managers who do not want this information shared with the public will choose to manage only unregistered investment vehicles, particularly if the proposal is revised to include some reference to the portfolio manager s net worth. Compiling the required information, particularly for fund groups that have funds with different fiscal year-ends, may prove quite burdensome. With respect to the portfolio manager s securities ownership, as well as the information regarding other accounts managed and compensation structure, the proposals require that the information be provided as of the fund s most recently completed fiscal year. Thus, funds would be required to update this disclosure annually. Funds would not be required to update their SAIs during the year, except to identify a new portfolio manager and provide the disclosure for that new manager. Similarly, an initial registration statement or an update to an existing registration statement that identifies a new portfolio manager (including post-effective amendments for a new series) would be required to include the disclosures as of the most recent practicable date and identify that date. AVAILABILITY OF INFORMATION AND ACCESS TO SAI The SEC also proposed to require, adjacent to the disclosure identifying the portfolio managers, new disclosure that the SAI provides additional information regarding portfolio managers compensation, other accounts managed by the portfolio managers, and the portfolio managers ownership of securities and other accounts managed by the investment adviser or portfolio managers. In addition, in order to encourage funds to provide greater access to investors to the SAI, the SEC also proposed to require that the back cover page of mutual fund prospectuses state whether the fund makes available its SAI and shareholder reports, free of charge, on or through its website at a specified Internet address. If it does not, it must disclose the reasons why it does not do so, including why the fund does not have a website. These proposals have the potential to penalize smaller firms that have not Kirkpatrick & Lockhart LLP 3

4 established websites. By requiring such disclosure, the SEC is effectively requiring firms to have the technology in place or risk being singled out for failing to do so. Funds may (but are not required to) indicate that the SAI, shareholder reports and other information are available by request. The SEC has proposed similar disclosure for the front cover page of the prospectus for closed-end funds and insurance company separate accounts that issue variable annuity contracts. The proposals also would require the front cover page of the prospectuses for these entities to include a statement explaining how the shareholder reports can be obtained, and a toll-free (or collect) telephone number for investors to call and request the SAI, shareholder reports and other information, and to make shareholder inquiries. DISCLOSURE RELATING TO PORTFOLIO MANAGERS OF INDEX FUNDS Currently, index funds are excluded from the requirement to identify and provide disclosure regarding their portfolio managers in fund prospectuses. Index funds were originally excluded from this requirement because of the mechanical nature of the portfolio management of these funds. The SEC proposals would extend to index funds the existing and proposed disclosure requirements relating to portfolio managers. The Proposing Release explains that such disclosure would assist investors in assessing whether the portfolio manager s interests are aligned with fund shareholders and the potential conflicts of interest involved in managing an index fund and other accounts, such as allocation of trading execution priorities. * * * This article does not address all of the issues raised by the proposed disclosure requirements. If you wish to obtain more information on the proposals, please contact your K&L relationship attorney or the author of this article, Lori Schneider, at (202) LORI SCHNEIDER lschneider@kl.com Kirkpatrick & Lockhart LLP 4

5 Kirkpatrick & Lockhart LLP maintains one of the leading investment management practices in the United States, with more than 60 lawyers devoting all or a substantial portion of their practice to this area and its related specialties. The American Lawyer Corporate Scorecard, published in April 2003, lists K&L as a primary legal counsel to the investment companies, board members or advisory firms for 15 of the 25 largest mutual fund complexes. No law firm was mentioned more frequently in the Scorecard. We represent mutual funds, closed-end funds, insurance companies, broker-dealers, investment advisers, retirement plans, banks and trust companies, hedge funds, offshore funds and other financial institutions. We also regularly represent mutual fund distributors, independent directors of investment companies and service providers to the investment management industry. In addition, we frequently serve as outside counsel to industry associations on a variety of projects, including legislative and policy matters. We work with clients in connection with the full range of investment company industry products and activities, including all types of open-end and closed-end investment companies, funds of hedge funds, variable insurance products, private and offshore investment funds and unit investment trusts. Our practice involves all aspects of the investment company business. We invite you to contact one of the members of the practice, listed below, for additional assistance. You may also visit our website at for more information, or send general inquiries via to investmentmanagement@kl.com. BOSTON Michael S. Caccese mcaccese@kl.com Philip J. Fina pfina@kl.com Mark P. Goshko mgoshko@kl.com Thomas Hickey III thickey@kl.com Nicholas S. Hodge nhodge@kl.com George Zornada gzornada@kl.com LOS ANGELES William P. Wade wwade@kl.com NEW YORK Philip L. Kirstein pkirstein@kl.com Beth R. Kramer bkramer@kl.com Richard D. Marshall rmarshall@kl.com Robert M. McLaughlin rmclaughlin@kl.com Keith W. Miller kmiller@kl.com Loren Schechter lschechter@kl.com SAN FRANCISCO Eilleen M. Clavere eclavere@kl.com Jonathan D. Joseph jjoseph@kl.com David Mishel dmishel@kl.com Mark D. Perlow mperlow@kl.com Richard M. Phillips rphillips@kl.com WASHINGTON Clifford J. Alexander calexander@kl.com Diane E. Ambler dambler@kl.com Mark C. Amorosi mamorosi@kl.com Catherine S. Bardsley cbardsley@kl.com Arthur J. Brown abrown@kl.com Arthur C. Delibert adelibert@kl.com Jennifer R. Gonzalez jgonzalez@kl.com Robert C. Hacker rhacker@kl.com Benjamin J. Haskin bhaskin@kl.com Kathy Kresch Ingber kingber@kl.com Rebecca H. Laird rlaird@kl.com Thomas M. Leahey tleahey@kl.com Cary J. Meer cmeer@kl.com R. Charles Miller cmiller@kl.com Dean E. Miller dmiller@kl.com R. Darrell Mounts dmounts@kl.com C. Dirk Peterson dpeterson@kl.com David Pickle dpickle@kl.com Alan C. Porter aporter@kl.com Theodore L. Press tpress@kl.com Francine J. Rosenberger francine.rosenberger@kl.com Robert H. Rosenblum rrosenblum@kl.com William A. Schmidt william.schmidt@kl.com Lori L. Schneider lschneider@kl.com Lynn A. Schweinfurth lschweinfurth@kl.com Donald W. Smith dsmith@kl.com Martin D. Teckler mteckler@kl.com Robert A. Wittie rwittie@kl.com Robert J. Zutz rzutz@kl.com Kirkpatrick & Lockhart LLP BOSTON... DALLAS HARRISBURG LOS ANGELES MIAMI NEWARK NEW YORK PITTSBURGH SAN FRANCISCO WASHINGTON This publication/newsletter is for informational purposes and does not contain or convey legal advice. The information herein should not be used or relied upon in regard to any particular facts or circumstances without first consulting a lawyer KIRKPATRICK & LOCKHART LLP. ALL RIGHTS RESERVED. Challenge us.

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