On October 28, 2020, the US Securities and Exchange Commission (SEC) voted 3–2 to adopt Rule 18f-4 (the Rule) under the Investment Company Act of 1940 (the Investment Company Act), which will replace decades-old SEC and staff guidance with an updated, comprehensive framework for registered funds’ use of derivatives.1 The Rule, which applies to mutual funds (other than money market funds), exchange traded funds (ETFs) registered under the Investment Company Act, and registered closed-end funds, as well as business development companies (collectively, Funds),2 responds to growth in the use, complexity, and variation of derivative instruments, and stands to substantially change the compliance and operations landscapes for Funds and their boards of directors or trustees (Boards).