Consultation Paper 4 - Conflicts of Interest (2015)

Independent Fund Directors are vital to safeguard investor interests. As the model of directorship has evolved, stakeholders must navigate new challenges to ensure strong governance.

In our response to this Consultation, we outline our thoughts on how existing industry practices could be improved to achieve the desired outcomes, while highlighting our concerns in relation to the publication of early details related to ongoing enforcement cases.

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.