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
On February 28, 2019, the staff of the Division of Investment Management (the "Staff") of the Securities and Exchange Commission (the "SEC") issued a no-action letter permitting the board of directors of a registered fund or...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 has issued a no-action letter permitting a fund’s board to rely on written representations from the fund’s CCO in lieu of quarterly determinations that the fund’s...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
How should fund directors monitor gifts and entertainment received by investment adviser personnel? This question moved to the forefront in February, when the Securities and Exchange Commission’s Division of Investment...more
On June 25, 2015, Luis Aguilar, a Commissioner at the U.S. Securities and Exchange Commission (“SEC”), provided remarks at the SINET Innovation Summit. In his remarks, Commissioner Aguilar emphasized the need for the public...more