Securities and Exchange Commission (SEC), Investment Funds, Fund of Funds

SEC Could Broaden Path to Private Equity Fund of Funds Investment

DarrowEverett LLP on 7/14/2025

Since the enactment of the Investment Company Act 85 years ago, the asset management industry has grown from $2 billion in assets to more than $39 trillion in assets. Under existing Securities and Exchange Commission (“SEC”)...more

SEC Adopts New Rule for Fund of Fund Arrangements

Skadden, Arps, Slate, Meagher & Flom LLP on 11/6/2020

On October 7, 2020, the Securities and Exchange Commission (SEC) adopted Rule 12d1-4 (Final Rule or Rule 12d1-4) under the Investment Company Act of 1940 (1940 Act) in an effort to streamline and enhance the regulatory...more

SEC Adopts Amendments Updating the ‘Fund of Funds’ Regulatory Framework for Registered Investment Companies and Business...

Herbert Smith Freehills Kramer on 10/14/2020

On Oct. 7, 2020, the Securities and Exchange Commission (SEC) voted to adopt a new rule (Rule 12d1-4), and related amendments to existing rules and forms, to enact a comprehensive regulatory framework for “fund of funds”...more

Game Changing Fund of Fund Reforms Ahead

Carlton Fields on 4/9/2019

On December 19, 2018, the SEC proposed rescinding most so-called fund of funds (FoF) exemptive orders and Rule 12d1-2 under the Investment Company Act of 1940 (Act) and replacing them with new Rule 12d1-4.1...more

Investment Services Regulatory Update - January 2019

Vedder Price on 1/30/2019

New Rules, Proposed Rules, Guidance and Alerts – PROPOSED RULES – SEC Proposes New Fund-of-Funds Rule – On December 19, 2018, the SEC proposed new Rule 12d1-4 under the Investment Company Act of 1940, which, if...more

Fund of funds flexibility - What’s important to BDCs and closed-end funds in the SEC’s rule proposal, including a request for...

Eversheds Sutherland (US) LLP on 1/15/2019

On December 19, 2018, the US Securities and Exchange Commission (SEC) issued a release (the Release) proposing new rule 12d1-4 (the Proposed Rule) and related amendments to streamline and enhance the regulatory framework that...more

No-Action Relief Granted for Three-Tier Fund Structure

Broker-Dealer Compliance + Regulation on 4/20/2015

The SEC’s Division of Investment Management on April 3, 2015, said that it will not recommend enforcement proceedings against an investment adviser that structures a three-tier fund allowing certain funds to invest in a...more

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