News & Analysis as of

No-Action Relief Investment Company Act of 1940

Seward & Kissel LLP

SEC Staff Grants No-Action Relief Under Section 17 and Rule 17d-1 Thereunder Allowing Fund to Enter Transaction Agreement with New...

Seward & Kissel LLP on

Who may be interested: Registered Investment Companies; Boards of Directors; and Investment Advisers. Quick Take: The staff of the SEC Division of Investment Management (Staff) recently issued a no-action letter stating...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Retrospective: 2020’s Second Half

In this issue, we provide a summary retrospective of regulatory, litigation and industry developments impacting the investment management sector during the second half of 2020, including SEC guidance and exemptive orders...more

Skadden, Arps, Slate, Meagher & Flom LLP

Withdrawal of Prior SEC Staff Letter on Control Share Statutes Clears Way for Closed-End Funds

On May 27, 2020, the staff of the Division of Investment Management (Staff) of the Securities and Exchange Commission (SEC) issued a statement regarding the intersection between state control share acquisition statutes...more

Faegre Drinker Biddle & Reath LLP

March 31, 2020 SEC Grants Emergency Liquidity Relief To Mutual Funds In Light Of COVID-19

On March 26, 2020, the Securities and Exchange Commission (SEC) issued No-Action Relief that allows an affiliated person of an open-ended investment company other than a money market fund or an exchange-traded fund to...more

Sullivan & Worcester

SEC Adopts Final ETF Rule to Streamline and Ease Product Development

Sullivan & Worcester on

On September 26, 2019, the Securities and Exchange Commission (“SEC”) adopted a new rule to modernize the regulation of most exchange-traded funds (“ETFs”). Rule 6c-11 (the “Rule”) under the Investment Company Act of 1940, as...more

Dechert LLP

SEC Provides No-Action Relief for Index-Based Funds to Exceed Diversification Limits without Obtaining Shareholder Approval

Dechert LLP on

As set forth in the Incoming Letter, during the past year certain constituents of large-capitalization U.S. equity growth broad-based indices (namely, certain technology-related companies) had grown to represent more than 5%...more

Eversheds Sutherland (US) LLP

And now for some good news - SEC no-action position provides limited relief for fund in-person voting requirements

On February 28, 2019, the Chief Counsel’s Office of the Securities and Exchange Commission’s Division of Investment Management issued a letter stating its no-action position regarding certain in-person voting requirements...more

Perkins Coie

SEC Staff Relaxes Certain In-Person Board Voting Requirements for Registered Investment Companies

Perkins Coie on

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

Dechert LLP

SEC Provides No-Action Relief from Certain Fund Director In-Person Meeting Requirements

Dechert LLP on

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

Proskauer Rose LLP

Analysis of the SEC’s MiFID II No-Action Relief

Proskauer Rose LLP on

On October 26, 2017, the Securities and Exchange Commission ("SEC" or the "Commission") staff issued three no-action letters to help broker-dealers, investment advisers and investment companies comply with the European...more

K&L Gates LLP

Cross Border Master-Feeder Arrangements: SEC Staff Slightly Expands Utility of Offshore Feeders for Global Investment Management...

K&L Gates LLP on

On March 8, 2017, the staff of the Securities and Exchange Commission (“SEC”) granted no-action relief that potentially will permit global investment management firms to offer U.S. registered open-end management investment...more

Carlton Fields

SEC Reconsiders Exchange-Traded Products

Carlton Fields on

The SEC recently published myriad questions about the listing, trading, and marketing (especially to retail investors) of "new, novel, or complex" exchange-traded products (ETPs). Such ETPs include exchange-traded funds...more

Morrison & Foerster LLP

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

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...more

Goodwin

SEC Staff Grants No-Action Relief to Permit Fund to Implement Subadvisory Arrangement Prior to Shareholder Approval

Goodwin on

The staff of the SEC’s Division of Investment Management granted no-action relief from Section 15(a) of the Investment Company Act of 1940, as amended (the “1940 Act”), that will permit a registered fund (the “Fund”) to enter...more

Goodwin

SEC Staff Grants No-Action Relief to Affiliated Securities Lending Agent

Goodwin on

The staff of the SEC’s Division of Investment Management granted no-action relief from Section 17(e)(1) of the Investment Company Act of 1940 (the “1940 Act”) to permit an affiliated securities lending agent to negotiate...more

Broker-Dealer Compliance + Regulation

No-Action Relief Allows Business Development Companies to Hold Shares of Investment Advisers

In two separate no-action letters, the SEC staff quietly expanded the ability of business development companies (BDCs) to invest in registered investment advisers. Section 12(d)(3) of the Investment Company Act of 1940...more

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