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SEC Rule Proposal: Good Faith Determinations of Fair Value Under the Investment Company Act

The U.S. Securities and Exchange Commission on April 21, 2020 proposed a long-anticipated framework for fair valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish...more

Newsflash: SEC Proposes Fund Valuation Rule

On April 21, 2020, the U.S. Securities and Exchange Commission proposed a long-anticipated framework for valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish requirements...more

Fund Boards May Rely on CCO Representations in Lieu of Quarterly Board Determinations Under Rules 10f-3, 17a-7 and 17e-1

The Staff of the SEC’s Division of Investment Management has issued a no-action letter permitting a fund’s board to rely on written representations from the fund’s CCO in lieu of quarterly determinations that the fund’s...more

The 15(c) Process Continues to be a Focus of the SEC Enforcement Staff

Two recent SEC Enforcement Division administrative settlements reinforce the importance for fund boards of directors and fund advisers to maintain a robust annual advisory contract renewal process....more

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