BDC Master Feeder Funds on the Horizon – No-Action Relief Granted to One Issuer

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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 available to future Feeder Funds in the same structure.

Although the staff granted the requested relief in this case, it said that other BDCs cannot rely on this relief. Thus, other BDCs that wish to utilize a master-feeder structure will have to seek separate relief. The staff indicated that it was “willing to consider similar requests from other BDCs.”

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