Adviser Business Continuity and Transition Plans

The Securities and Exchange Commission ("Commission' or "SEC') is proposing a new rule and rule amendments under the Investment Advisers Act of 1940 ("Advisers Act'). The proposed rule would require SEC-registered investment advisers to adopt and implement written business continuity and transition plans reasonably designed to address operational and other risks related to a significant disruption in the investment adviser's operations. The proposal would also amend rule 204-2 under the Advisers Act to require SEC-registered investment advisers to make and keep all business continuity and transition plans that are currently in effect or at any time within the past five years were in effect.