Streamlining 15(c) Reporting | Salvatore Faia Insights
Vigilant Insights
Introduction
Fund Boards are increasingly reevaluating the volume and relevance of their Annual 15(c) Materials, working to eliminate redundant or obsolete information, streamline lengthy questionnaires, and rely more on dashboard-style tools to navigate the hundreds of pages typically involved in the review process.
With growing pressure to modernize their processes, many Boards are working to eliminate redundant reporting, streamline the flow of information, and focus on what truly drives effective oversight.
Recent industry developments, such as the rise of active ETFs for example, are shifting SEC priorities around fees and costs, and workflow changes that emerged during the pandemic have accelerated efforts to simplify 15(c) Materials.
Many Boards are adopting dashboard-style tools, revisiting the structure of their questionnaires, and reassessing long-standing reporting practices to ensure their reviews remain both efficient and meaningful.
Ultimately, Boards are striving to concentrate on what is materially necessary rather than being weighed down by hundreds of pages of information that may not serve the decision-making process.
Our President & CEO, Salvatore Faia, Esq., CPA, CFE, shared his insights on 15(c) Reporting with Fund Directions (a With Intelligence publication). A summary of his key points is provided below.
Salvatore Faia Insights
Salvatore noted that as Boards evaluate their 15(c) processes, they are increasingly recognizing that certain questions and materials are more important than others under the Gartenberg standard. He emphasized that not all items included in lengthy questionnaires carry equal significance, and Boards are beginning to take a more discerning approach.
Salvatore explained that many Boards are reducing unnecessary paperwork by relying on their Compliance Firms (like Vigilant) or Counsel to review extensive documents before they reach Directors. For example, a Form ADV may run 100 pages, but by having a Compliance Firm first review the document and confirm that everything appears appropriate, Boards can avoid being overwhelmed by volume and instead focus on the most substantive and relevant information.
His perspective underscores a larger shift across the industry: Boards want clarity, efficiency, and materiality. By narrowing their attention to the information that truly matters, Directors can dedicate more time to thoughtful oversight and less time navigating through unnecessary detail.
Vigilant’s Conclusion
The movement toward streamlined 15(c) processes reflects a broader commitment across the Fund Governance landscape to prioritize effectiveness over excess.
Boards are leveraging dashboards, simplifying questionnaires, forming pre-meeting review groups, and adopting technology that makes information easier to digest. These improvements allow Directors to focus on issues that have real impact, rather than being buried under administrative overload.
Vigilant supports Boards in this evolution by providing Trust CCO and Fund CCO Services, helping determine which materials are most essential and by conducting expert reviews of extensive regulatory documents so Directors can concentrate on the areas that matter most.
As regulatory expectations continue to evolve and new Fund Structures emerge, a targeted, well-organized 15(c) Review Process positions Boards to operate with enhanced clarity, confidence, and efficiency.
This streamlined approach ultimately strengthens Fund Oversight and helps the Board’s time be spent where it delivers meaningful value to shareholders.