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Goodbye to All That: SEC Adopts Rules Overhauling Funds' Use of Derivatives; Ends Asset Segregation

USA - November 12 2020 On 28 October 2020, the U.S. Securities and Exchange Commission adopted Rule 18f-4 under the Investment Company Act of 1940, as amended. The rule…

Britney E. Ryan, Kenneth Holston, Matthew J. Rogers, Michael W. McGrath.

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

USA - October 26 2020 On 7 October 2020, the Securities and Exchange Commission (the SEC) adopted new rule 12d1-4 (Rule 12d1-4) and related amendments…

Abigail P. Hemnes, George Zornada, Jannay D. Johnson, Jennifer A. DiNuccio, Jennifer R. Gonzalez, Jon-Luc Dupuy, Jordan A. Knight, Mark P. Goshko.

SEC Staff No-Action Letter Eases Board’s Burden in Reviewing Affiliated Transactions

USA - November 1 2018 On October 12, 2018, the staff of the Division of Investment Management (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued a…

Christopher R. Bellacicco, Lori L. Schneider.

SEC Amends Liquidity Rule Reporting and Disclosure Requirements

USA - July 25 2018 On June 28, 2018, the Securities and Exchange Commission (“SEC”) amended certain disclosure requirements related to the “Liquidity Rule” — Rule 22e-4…

Jin H. Ahn.

SEC Delays Certain Liquidity Rule Requirements and Issues Guidance Regarding Illiquid Security Determinations

USA - April 10 2018 On February 22, 2018, the Securities and Exchange Commission (“SEC”) adopted an interim rule (“Interim Rule”) that revised compliance dates for…

Michael M. Hart-Slattery, Peter J. Shea, Timothy A. Bekkers.