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Valuation No-Action Letters

Sullivan & Worcester

SEC Adopts New Valuation Rule under the 1940 Act

Sullivan & Worcester on

On December 3, 2020, the Securities and Exchange Commission (SEC) adopted new rule 2a-5 ("Rule 2a-5") under the Investment Company Act of 1940, as amended ("1940 Act") addressing valuation practices and the board of...more

Dechert LLP

SEC Rule Proposal: Good Faith Determinations of Fair Value Under the Investment Company Act

Dechert LLP on

The U.S. Securities and Exchange Commission on April 21, 2020 proposed a long-anticipated framework for fair valuation of fund investments. Proposed Rule 2a-5 under the Investment Company Act of 1940 would establish...more

Orrick - Finance 20/20

CFTC Extends No-Action Relief to Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations

Orrick - Finance 20/20 on

On June 15, CFTC Division of Market Oversight published a letter extending the time-limited relief provided by previously issued no-action letter 14-90, expiring on June 30, 2015, to June 30, 2016. The relief applies to the...more

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