This Alert focuses on special considerations for closed-end funds registered under the Investment Company Act of 1940, as amended (the ‘1940 Act’), arising from COVID-19 (coronavirus) and related regulatory relief of interest...more
On March 25, 2020, the Securities and Exchange Commission (“SEC”) issued an exemptive order (the "Order") superceding its March 13, 2020 exemptive order, which provided relief from certain provisions of the Investment Company...more
On March 13, 2020, the staff of the Securities and Exchange Commission (“SEC”) issued an exemptive order providing relief from certain provisions of the Investment Company Act of 1940, as amended (the “1940 Act”), to...more
3/17/2020
/ Coronavirus/COVID-19 ,
Corporate Governance ,
Disclosure Requirements ,
Emergency Response ,
Exemptive Relief ,
Filing Requirements ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Funds ,
Notice Requirements ,
Prospectus ,
Securities and Exchange Commission (SEC) ,
Virtual Meetings
On November 25, 2019, the SEC proposed a new exemptive rule under the Investment Company Act of 1940—Rule 18f-4—intended to overhaul the current regulatory framework governing the use of derivatives by registered investment...more
On November 25, 2019, the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) re-proposed a new exemptive rule under the Investment Company Act of 1940, as amended (the “1940 Act”)—Rule 18f-4 (the...more
12/23/2019
/ Broker-Dealer ,
Business Development Companies ,
Derivatives ,
ETFs ,
Exemptive Orders ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Companies ,
Investment Company Act of 1940 ,
Investment Fund Vehicles ,
Investment Funds ,
Investment Management ,
Proposed Rules ,
Public Comment ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
On September 26, 2019, the Securities and Exchange Commission (the “SEC”) adopted Rule 6c-11 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”), the long-awaited “ETF Rule.” ETFs that satisfy certain...more
10/1/2019
/ ETFs ,
Exchange-Traded Products ,
Exemptive Orders ,
Final Rules ,
Foreign Investment ,
Investment Company Act of 1940 ,
Investment Management ,
New Rules ,
Registration Statement ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Transparency
On March 20, 2019, the U.S. Securities and Exchange Commission (“SEC”) proposed a series of reforms to the registration and offering processes for registered closed-end investment companies (“Registered CEFs”). The proposal...more
5/7/2019
/ Closed-End Funds ,
Investment Company Act of 1940 ,
Offering Communications ,
Proposed Amendments ,
Proposed Rules ,
Prospectus ,
Registration Statement ,
Reporting Requirements ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
I. Executive Summary -
Overview -
The Securities and Exchange Commission (the “Commission”) proposed Rule 6c-11 (the “Proposed Rule”) under the Investment Company Act of 1940, as amended (the “1940 Act”),1 if adopted,...more
9/14/2018
/ Comment Period ,
Disclosure Requirements ,
ETFs ,
Exemptive Orders ,
Investment Company Act of 1940 ,
Investment Management ,
Investors ,
Policies and Procedures ,
Proposed Rules ,
Public Comment ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Websites