SEC Takes Further Action to Assist Funds in Light of COVID-19 Coronavirus Pandemic: Provides Flexibility for Funds and Insurance Company Separate Accounts to Obtain Short-Term Funding

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On March 23, 2020, the Securities and Exchange Commission issued an order providing relief to registered open-end funds and insurance company separate accounts (separate accounts) registered as unit investment trusts. The Order follows two previous orders by the SEC, granted on March 13, 2020, which provided relief to funds and investment advisers whose operations may be affected by the COVID-19 coronavirus outbreak.

Designed to provide additional flexibility in obtaining short-term funding, the Order:

- Permits funds (other than money market funds) and separate accounts to borrow from certain affiliates;

- Allows funds to use interfund lending arrangements, and expands relief to funds that already have existing interfund lending exemptive relief; and

- Authorizes funds (other than money market funds) to participate in certain lending arrangements or borrowings that deviate from their fundamental policies.

The relief will remain in effect at least through June 30, 2020. Its termination date will be specified in a subsequent public notice from the SEC Staff, with at least two weeks advance notice.

Please see full Publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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