On May 4, 2020, the U.S. Internal Revenue Service issued Revenue Procedure 2020-19, temporarily allowing publicly offered regulated investment companies (RICs), including certain business development companies and certain...more
While the IRS's Proposed Regulations Are Not Yet Effective, RICs Should Carefully Consider Whether Their Portfolios or Policies Run Afoul of the New Rules. In order for a corporation to qualify as a regulated investment...more
The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more
The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more
Under guidance issued on July 16, 2015 by the federal agencies responsible for implementing the Volcker Rule (the “Agencies”) RICs and FPFs need not be treated as banking entities during a seeding period of up to three years....more
Emphasizing the critical importance of cybersecurity to registered investment companies (RICs), including insurance separate accounts and business development companies, and to investment advisers, the SEC’s Division of...more
On December 10, 2013, the U.S. Federal Reserve, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Commodity Futures Trading Commission, and the Securities and Exchange Commission...more
The CFTC adopted rule amendments (the “Harmonization Rule”) designed to harmonize certain CFTC compliance obligations that apply to commodity pool operators (“CPOs”) of investment companies registered under the Investment...more
On August 13, 2013, the Commodity Futures Trading Commission (CFTC) adopted amendments to certain provisions of Part 4 of the CFTC regulations that are applicable to all commodity pool operators (CPOs) and commodity trading...more
Eighteen months after amending CFTC Regulation 4.5 to narrow the registered investment company (RIC) exclusion from the definition of commodity pool operator (CPO) and issuing a companion release proposing to amend certain...more