News & Analysis as of

Form N-PORT Rule 18f-4

Carlton Fields

A New Beginning for Fund Derivative Regulation

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SEC Replaces Rather than Revises - In late October, the SEC approved a wholesale replacement for the patchwork of interpretive and no-action positions it had developed over more than 40 years to regulate fund use of...more

Sullivan & Worcester

SEC Adopts New Rules on Investment Company Use of Derivatives

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he U.S. Securities and Exchange Commission (the “SEC”) recently adopted new rules and rule and form amendments under the Investment Company Act of 1940 (the “1940 Act”) relating to, among other things, use of derivatives and...more

Kilpatrick

SEC Adopts Derivatives Overhaul for Funds

Kilpatrick on

On October 28, 2020, the Securities and Exchange Commission (“SEC”) finalized Rule 18f-4 under the Investment Company Act, a new rule designed to provide an updated and comprehensive framework for the use of derivatives by...more

Troutman Pepper

Investment Management Update - January 2020

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SEC Proposes to Update Accredited Investor Definition to Increase Access to Investments - On December 18, 2019, the Securities and Exchange Commission (SEC) proposed amendments to the definition of “accredited investor” in...more

Proskauer Rose LLP

SEC Re-Proposes Regulations Governing the Use of Derivatives and Other Transactions by Registered Funds and BDCs

Proskauer Rose LLP on

The Securities and Exchange Commission (the "SEC") recently proposed a revised version of new Rule 18f-4 (the "Proposed Rule") under the Investment Company Act of 1940, as amended (the "1940 Act"), which it originally...more

Sullivan & Worcester

SEC Re-Proposes Investment Company Derivatives Rule under the Investment Company Act

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The U.S. Securities and Exchange Commission (the “SEC”) re-proposed on November 25, 2019 rules under the Investment Company Act of 1940 (the “1940 Act”) relating to, among other things, use by investment companies of...more

Dechert LLP

SEC Proposes New Rules and Amendments to Update the Approach to the Regulation of Funds’ Use of Derivatives and Other Transactions

Dechert LLP on

The U.S. Securities and Exchange Commission on November 25, 2019 approved for publication a three-part rule proposal related to the use of derivatives and certain other transactions by registered investment companies (i.e.,...more

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