Podcast: Credit Funds: 1940 Act Interval Funds
The Securities and Exchange Commission (the “SEC”) staff recently announced that the Division of Investment Management (the “Division”) will no longer require registered closed-end funds that invest in private funds...more
Our Investment Funds Team explains the Securities and Exchange Commission new guidance that expands retail investor access to private funds by relaxing previous restrictions....more
On August 15, 2025, the staff of the SEC’s Division of Investment Management (the “Staff”) published a new Accounting and Disclosure Information (“ADI”) regarding registered closed-end funds of private funds (“CE-FOPFs”)....more
As previously described in a May Ropes & Gray Alert, the SEC staff no longer requires retail closed-end funds to limit their investments in private funds – i.e., funds relying upon Sections 3(c)(1) or 3(c)(7) of the 1940 Act...more
On August 15, 2025, the Division of Investment Management (the “Division”) of the U.S. Securities and Exchange Commission (SEC) published Accounting and Disclosure Information 2025-16 (ADI), providing updated guidance for...more
Who may be interested: Registered Closed-End Funds, Registered Investment Advisers, Compliance Staff, Boards of Directors, Broker-Dealers, Private Fund Managers - Quick Take: The Securities and Exchange Commission (the...more
On June 30, 2025, the Supreme Court granted certiorari in FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd., agreeing to resolve a circuit split over whether private parties have an implied right of action to...more
Recent policy initiatives and remarks from leaders of the US Securities and Exchange Commission (SEC) have created a changing landscape for retail access to the private markets. At a recent conference hosted by the Practising...more
Since our prior IM Update, in separate Alerts, we covered (i) the SEC’s decision to remove from its regulatory agenda proposed rulemakings relevant to the investment management industry, (ii) Ropes & Gray’s updated and...more
In today’s evolving investment landscape, institutional investors are increasingly seeking innovative structures that align with regulatory requirements while maximizing returns. One such structure gaining traction is the...more
Since 2002, the staff of the US Securities and Exchange Commission (SEC) consistently issued comments during the registration statement review process to closed-end funds (CEFs) registered under the Investment Company Act of...more
On April 29, 2025, the U.S. Securities and Exchange Commission ("SEC") issued an order granting Franklin Square's ("FS") exemptive relief application (the "FS Application") permitting certain business development companies...more
Our Investment Funds Team discusses Securities and Exchange Commission Chair Paul Atkins’s plans to improve retail investors’ access to private funds....more
At yesterday's Practising Law Institute’s SEC Speaks program, Securities and Exchange Commission (“SEC”) Chair Paul Atkins shared his views on a wide range of topics. Chair Atkins touched on innovation at the SEC, FinHub and...more
Investment funds have a variety of legal structures customized to investors’ various needs and investment policies. The two main fund structures are closed-end funds and open-end funds, which differ in several material...more
On April 3, 2025, the U.S. Securities and Exchange Commission (“SEC”) issued a notice of proposed exemptive relief to FS Credit Opportunities Corp. and its affiliates (Applicants), introducing more flexible co-investment...more
The growth of the operational real estate (OpRE) sector is one of the most significant recent trends in global real estate markets. OpRE is relevant to a wide range of real estate asset classes and subsectors, but all OpRE...more
As noted in our previous article, the lifespan of a closed-end fund typically ranges from 8 to 12 years, depending on the asset class. However, to provide flexibility to deal with issues related to illiquidity of assets,...more
The recent closing by Goldman Sachs of its highly innovative and market leading US$475 million “capital call” securitisation of subscription credit lines has generated a lot of interest in both fund finance and structured...more
ケイマン諸島は世界有数のオフショアファンド法域です。2023年時点でのケイマン諸島における登録ファンド数は約29,500で、ケイマン諸島籍ファンドは、全世界の米国籍以外のファンド全体の68%を占めています。...more
The Cayman Islands is a pre-eminent offshore funds jurisdiction. In fact, with around 29,500 registered funds in 2023, Cayman accounts for 68% of funds set up outside of the United States....more
In light of recent attention to closed-end fund governance in general and to bylaws in particular, we offer this brief reminder of the value of a periodic review of the bylaws of Maryland corporations and statutory trusts...more
Investors in closed-end funds make a commitment for the duration of a fund’s life cycle — known as the fund’s term — with liquidity available only through sale of assets, secondary transactions, or fund liquidation. Investors...more
Our investment funds team outline the latest developments within the investment funds market in the British Virgin Islands ("BVI"), including the funds statistics from the British Virgin Islands Financial Services Commission...more
Our investment funds team outline the latest developments within the investment funds market in Bermuda, addressing the recent statistics from Q2 2024 published by the Bermuda Monetary Authority (the "BMA") as well as the...more