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Email A recent order by the Securities and Exchange Commission strongly suggests that registered investment advisers that rely upon quantitative investment models to manage client assets are required by the Investment Advisers Act of 1940 to implement written compliance policies and procedures in order to identify and mitigate the risks associated with their quantitative models. https://www.cadwalader.com/resources/clients-friends-memos/quantitative-investment-models-and-compliance-policies-and-procedures-the-securities-and-exchange-commission-order-involving-the-axa-rosenberg-entities