PERAC Memo #14 - 2014: Investor Registration with the Securities Exchange Commission Massachusetts Secretary of State

Investor Registration with the Securities Exchange Commission Massachusetts Secretary of State

Summary

PERAC Memorandum #14, 2014 announces that the Commission voted to require SEC (or, where applicable, Massachusetts Secretary of State) registration as a prerequisite for issuing an Acknowledgement Letter for any proposed investment. Boards should note that they may not proceed with an investment in an entity that lacks such registration, since PERAC will withhold the Acknowledgement Letter in these circumstances; boards should therefore verify an investment manager's SEC or SOS registration status before submitting investments for approval.

Full Text

MEMORANDUM #14, 2014 Robert B. McCarthy M E M O R A N D U M TO: All Retirement Boards FROM: Joseph E. Connarton, Executive Director RE: Investor Registration with the Securities Exchange Commission Massachusetts Secretary of State DATE: April 8, 2014 On March 13, 2014, at its regular monthly meeting, the PERAC Commissioners unanimously voted to approve the following motion: A retirement board that seeks to invest funds with an entity that is not registered with the Securities and Exchange Commission (“SEC”) or, if applicable, the Massachusetts Office of the Secretary of State (“SOS”) will not receive an Acknowledgement Letter from the Commission and therefore may not make such an investment as the Commission has made a determination that it is in the best interest of the retirement system to withhold the Acknowledgement in circumstances in which a retirement board seeks to invest with a non-registered entity. Those investment advisers who do not qualify for SEC registration are required to register with the SOS. If you have any questions please contact this office.