On November 4, 2019, the Office of the Chief Counsel of the SEC's Division of Investment Management extended the temporary no-action relief from compliance with the registration and other provisions of the Investment Advisers...more
As set forth in the Incoming Letter, during the past year certain constituents of large-capitalization U.S. equity growth broad-based indices (namely, certain technology-related companies) had grown to represent more than 5%...more
The SEC’s Division of Investment Management has relaxed certain in-person voting requirements for fund boards, subject to certain conditions, in a no-action letter to the Independent Directors Council (the IDC) issued on...more
The Staff of the SEC’s Division of Investment Management (Staff) has issued a no-action letter permitting a registered fund’s board of directors (board) in certain circumstances to meet telephonically, by video conference or...more
The staff of the SEC’s Division of Investment Management said that it would not recommend enforcement action if a business development company (BDC) reorganizes into a master-feeder structure. The relief will also be...more