In a recent speech, Director of the SEC’s Division of Investment Management David Grim stated that fund directors are “always at the front of my mind.” Grim emphasized that the role of a fund director is one of oversight and not “day-to-day management of a fund.” He acknowledged “that if directors are overly burdened with a management function, they can’t effectively serve in their intended capacity.” Grim suggested that the SEC staff focuses on “providing directors with the tools they need to effectively oversee funds” when developing policy recommendations and guidance, pointing specifically to the recent guidance on sub-accounting fees and cybersecurity. He also highlighted the proposed requirements for fund boards in the recent liquidity and derivatives releases, calling the role “vital and focused on oversight.”
