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Investment Company Act of 1940 Investment Management Filing Requirements

Ropes & Gray LLP

SEC Issues New Guidance for Registered Closed-End Funds Investing in Private Funds

Ropes & Gray LLP on

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

Morrison & Foerster LLP

SEC Rescinds Staff Position Limiting Registered Closed-End Funds’ Investments in Private Funds

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

Proskauer Rose LLP

SEC Adopts Expedited Exemptive Relief Process for Registered Funds and BDCs

Proskauer Rose LLP on

On July 6, 2020, the Securities and Exchange Commission (the “Commission”) adopted rule amendments (the “Amendments”) to the exemptive relief application process under the Investment Company Act of 1940, as amended (the “1940...more

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