Once upon a time, in 1994, when I was a young lawyer in the SEC’s Division of Investment Management (Division), Office of Chief Counsel, we received a request to modify a previously granted but totally impractical no-action...more
On April 21, 2020, the Securities and Exchange Commission (SEC) voted to propose Rule 2a-5 under the Investment Company Act of 1940 (1940 Act) setting forth a new framework for funds’ fair value determinations (Proposed Rule)...more