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SEC Extends Compliance Period for the Amended Names Rule

On 14 March 2025, the Securities Exchange Commission (SEC) extended the compliance dates for the amendments to Rule 35d-1 (Amended Names Rule) under the Investment Company Act of 1940, as amended (1940 Act), by six months....more

A Deep Dive into Money Market Fund Liquidity Fees

Executive Summary - On 12 July 2023, the Securities and Exchange Commission (the SEC) adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Final Rule), which governs the...more

Out With the Old, in With the New – SEC Scraps Swing Pricing Proposal, Removes Redemption Gates, and Mandates Liquidity Fees for...

In a surprising change, the SEC heeded the cacophony of opposition to swing pricing, but instead threw the industry a curveball by requiring mandatory liquidity fees for institutional prime and institutional tax-exempt money...more

Proposed Money Market Fund Reforms Related to Negative Interest Rates Favor Conversion to Floating NAV and Prohibit Other...

On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which governs the structure and...more

SEC Proposes Swing Pricing for Institutional Money Market Funds

SECTIONS - I. Introduction - II. Key Requirements for Swing Factor Implementation - III. When a Swing Factor Must Be Applied - IV. Calculation of the Swing Factor - V. The President’s Working Group 2020 White Paper and Prior...more

SEC Proposes Another Round of Money Market Fund Reforms

I. EXECUTIVE SUMMARY - On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which...more

Fund of Funds Rule Adoption—A Deeper Dive Into the Impact of Rule 12d1-4 on Closed-End Funds and Business Development Companies

I. INTRODUCTION - On October 7, 2020, the Securities and Exchange Commission (SEC) adopted new rule 12d1-4 (Rule 12d1-4) and related amendments under the Investment Company Act of 1940 (as amended, the 1940 Act) in an effort...more

SEC Adopts New Rule 12d1-4 Overhauling Fund of Funds Arrangements--Are You Ready?

I. EXECUTIVE SUMMARY - On 7 October 2020, the Securities and Exchange Commission (the SEC) adopted new rule 12d1-4 (Rule 12d1-4) and related amendments under the Investment Company Act of 1940 (the 1940 Act) that it believes...more

Offering Reforms or Burdensome Regulations? It Depends!

SEC Proposes Reforms for Registration Process of Closed-End Funds and Business Development Companies - On March 20, 2019, the Securities and Exchange Commission (“SEC”) proposed several rules (the “Proposed Rules”) that...more

Saving Trees: SEC Allows Notice & Access Delivery of Shareholder Reports

On June 4, 2018, the Securities and Exchange Commission (the “SEC”) voted to adopt new Rule 30e-3 (the “Rule”) under the Investment Company Act of 1940, as amended (the “1940 Act”)....more

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