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
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
On October 28, the Securities and Exchange Commission (the “SEC”) adopted Rule 18f-4 (the “Rule”) under the Investment Company Act of 1940 (the “1940 Act”) and amended related rules designed to provide a modernized,...more
On October 28, 2020, the U.S. Securities and Exchange Commission (the SEC) voted 3-2 to adopt Rule 18f-4 (the Final Rule) under the Investment Company Act of 1940 (the 1940 Act), which establishes a comprehensive framework...more
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
The Securities and Exchange Commission (SEC) voted 3-2 on October 28, 2020 to adopt Rule 18f-4 under the Investment Company Act of 1940, as amended (1940 Act), and related amendments (Rule 18f-4 or Final Rule) related to the...more
The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more
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
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
On Nov. 25, 2019 the Securities and Exchange Commission (SEC) voted to propose a new rule, under the Investment Company Act of 1940 (the “1940 Act”), designed to modernize the way the SEC regulates the use of derivatives by...more
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
In December 2015, the Securities and Exchange Commission (the SEC) proposed a new Rule 18f-4 under the Investment Company Act of 1940 (the 1940 Act) that would, if adopted, affect the ability of mutual funds, exchange-traded...more
On December 11, 2015, the Securities and Exchange Commission (Commission) proposed a rule that, if adopted, would rescind nearly 30 years of Commission and staff guidance that is currently relied upon by most mutual funds,...more