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Vedder Thinking | Articles Remarks of Dalia Blass, Director of the SEC’s Division of Investment Management, at the SEC Regulation Think-In 2020 Conference


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Dalia Blass, Director of the SEC’s Division of Investment Management, provided remarks at the SEC’s Regulation Think-In 2020 Conference that was held online on September 16, 2020. Her remarks focused on international policy, including the Division staff’s collaboration with international organizations and regulators and monitoring of the effects of foreign policy on SEC-regulated entities, particularly in light of the COVID-19 pandemic. As an example, she noted that information on the use of swing pricing by certain European funds as a liquidity risk management tool could help the Division determine the potential benefits of implementing swing pricing in the United States. Ms. Blass discussed recent MiFID II rule amendments in response to COVID-19 pertaining to research on small- and mid-cap European companies and European fixed-income instruments that would permit investment firms to make joint payments for research and execution under certain conditions.

Ms. Blass encouraged asset managers and other industry participants to engage with the Division or their local regulators, citing the benefits of having a wide range of perspectives when the Division staff engages with international regulators. She stated that the Division staff has engaged extensively with asset managers and broker-dealers regarding the impact of regulatory changes on research coverage and quality, and has encouraged those firms to reach out to the staff if their views have changed in light of the no-action letter issued on November 4, 2019 that extended certain temporary relief previously issued to investment managers subject to MiFID II or in light of other developments in market practice. Ms. Blass concluded by renewing the Division’s request for data and other information concerning how MiFID II’s research provisions are affecting various market participants, stating that more hard data allows the Division staff to better assess policy options.

A transcript of Ms. Blass’s remarks is available here.


John S. Marten


Nathaniel Segal


Jacob C. Tiedt


Mark A. Quade