November 4, 2022 marked the deadline for compliance with amended
Rule 206(4)-1 ( e "Marketing
Rule")1 under the ve me Adv er Ac of 1940
( e "Advisers Act"), mpo additional
obligations on certain investment advisers registered
("RIAs") with the U.S. Securities and
Exchange Commission (the "SEC") a d e r
rely adv er ("Relying
Advisers")2 .
In this client alert, we examine the impact of the Marketing
Rule on the collateralised loan obligation
("CLO") industry, the additional
implications that European CLO market participants will need to
consider, and how a consensus is developing between in-scope CLO ma
a er ("In-scope Managers") a d arra ba k
as to Marketing Rule compliance in the context of CLO marketing
activities.
