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SEC provides green light to new exemptive relief

The SEC recently issued a notice with regard to a new model of co-investment relief and issued the first exemptive order for multi-class relief to a private BDC. This legal alert discusses both new developments....more

The deadline for re-affirming CPO exemptions/exclusions is approaching

Under Commodity Futures Trading Commission (CFTC) regulations, persons who have claimed an exemption or exception from commodity pool operator (CPO) or commodity trading advisor (CTA) status pursuant to Part 4 of the CFTC’s...more

Dividends payable partly in stock may provide capital flexibility to BDCs

The COVID-19 pandemic has caused a significant disruption in the capital markets. As a result, business development companies (BDCs) may be seeking to conserve cash in order to preserve flexibility and respond to evolving...more

SEC provides immediate temporary flexibility to BDCs regarding asset coverage and co-investment in response to COVID-19 pandemic

On April 8, 2020, the staff of the Division of Investment Management of the US Securities and Exchange Commission (Commission) issued an exemptive order (the Order) under the Investment Company Act of 1940 (1940 Act) that...more

SEC proposes rule that would expand access to private BDCs 

On December 18, 2019, the Securities and Exchange Commission (SEC) issued a proposed rule – “Amending the ‘Accredited Investor’ Definition” (the Proposed Rule) – that would expand access to private funds for certain...more

BDCs must reclaim relief from CPO registration

On November 25, 2019, the Commodity Futures Trading Commission (CFTC) adopted several final regulations to codify existing exemptions from commodity pool operator (CPO) registration. Among them is an exemption that was issued...more

Everybody “Test-the-Waters” - SEC Expands Communications Rule to All Issuers

On September 26, 2019, the Securities and Exchange Commission (SEC) announced that it has expanded the “testing-the-waters” exemption to all issuers. The new rule and related amendments under the Securities Act of 1933, as...more

SEC proposes to expand “testing-the-waters” provisions to all issuers

On February 19, 2019, the Securities and Exchange Commission (SEC) announced a proposal to expand the “testing-the-waters” exemption to all issuers. Currently the exemption is limited to emerging growth companies (EGCs)....more

Springtime for BDCs - Congress passes long-sought legislation in spending bill

On March 23, 2018, Congress passed its omnibus spending bill, the Consolidated Appropriations Act of 2018, to fund the federal government until October. Included within the spending bill is legislation, titled the Small...more

Tax Reform Provisions Affecting BDCs and Closed-End Funds

As discussed in Eversheds Sutherland (US) LLP’s Quick Call: Legislative and Tax Reforms – What This Could Mean for Business Development Companies, Congress is currently negotiating a tax reform package that, if passed,...more

Choice 2.0 and Its Impact on Business Development Companies

In April 2017, the full text of an updated version of the CHOICE Act (CHOICE 2.0) was released followed by a hearing on its contents. On June 8, 2017, the House Financial Services Committee released the draft of CHOICE 2.0, a...more

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