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Rule 18f-4 Proposed Regulation

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

WilmerHale

SEC Considering Key Changes to Derivative Exposure Calculations

WilmerHale on

On November 1, 2016, the Securities and Exchange Commission's (SEC) Division of Economic and Risk Analysis (DERA) published additional economic analysis setting forth the methodology used to analyze certain comments received...more

Katten Muchin Rosenman LLP

SEC Proposed Rule 18f-4 Would Severely Restrict Use of Derivatives by Investment Companies

On December 11, 2015, the Securities and Exchange Commission proposed a new rule, Rule 18f-4, under the Investment Company Act (ICA), to regulate certain types of financial commitments made by investment companies, including...more

WilmerHale

SEC Proposes New Framework for Regulating Funds’ Use of Derivatives and Leverage

WilmerHale on

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

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