Discussions around trade errors, omissions, and breaches are sensitive given it is not a “zero failure” environment. In this memo, we explore the spectrum of approaches and treatment of these and highlight how investors and managers can improve dialogue for mutual success.
The SBAI expands on existing frameworks for GHG-emission accounting to develop a methodology that allows for the incorporation of derivatives and short positions. The framework outlines the case for inclusion from the perspective of measurement of GHG-emission risk exposure and sustainability outcomes (impact).
The Securities and Exchange Commission (SEC) has introduced new rules to address conflicts of interest when advisers offer investors the choice between selling or exchanging their interests in a private fund for interests in another vehicle managed by the adviser or related parties. In this piece, we explore the impacts of these new rules for investors and managers and highlight considerations for effective implementation.
Our initial assessment of the SEC's Private Fund Adviser Rule[1] is that while there is less prohibition and more disclosure, it remains overly prescriptive. While some controversial aspects in the original proposal have been modified, the rules will bring significant changes to the regulation of Private Fund Advisers that may still fail to address the root of governance failures.
SBAI responds to FCA’s Discussion Paper on Diversity and Inclusion in the Financial Sector, focusing on Qualitative vs Quantitative Data, Regional Differences, Proportionality, and Standardisation.
