July 15, 2015

SEC Issues No-Action Letter Allowing Unique Master-Feeder BDC

The SEC granted no-action relief to Carey Credit Advisors, LLC (Adviser) and Guggenheim Partners Investment Management, LLC (Sub-Adviser), allowing them to offer a business development company (“BDC”) structured as a master-feeder fund arrangement. The assets of each feeder fund will be pooled into a single master fund. The feeder fund will have a finite term and a target liquidation date, allowing the Adviser and Sub-Adviser to manage the maturity and duration of the master fund’s fixed income portfolio efficiently to generate the necessary liquidity to fund the known upcoming liquidation. The master-feeder structure also will provide the sub-adviser with the ability to manage the liquidity of the master fund based on the liquidity being provided by the feeder funds.

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July 7, 2015

SEC Brings 9(a) Order Against Affiliates of an Investment Company Complex

The SEC brought an enforcement action against Macquarie Capital Investment Management LLC, an adviser to a number of mutual funds, Delaware Management Company, Delaware Investments Fund Advisers, Four Corners Capital Management, LLC (FCCM), Macquarie Funds Management Hong Kong Limited, and Delaware Distributors, L.P. (collectively, the Macquarie Affiliates), each of which provide services to mutual funds, pursuant to Section 9(f) of the 1940 Act

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July 1, 2015

SEC Brings Auditor Independence Violation Charge Against Deloitte, ALPS and Audit Committee Member

The SEC charged Deloitte & Touche LLP with violating auditor independence rules when its consulting affiliate maintained a business relationship with a trustee serving on the boards and audit committees of three funds it audited.  The SEC also charged a trustee and audit committee member, Andrew C. Boynton, with causing related reporting violations by the funds. In addition, the SEC charged the funds’ administrator ALPS Fund Services with causing related compliance violations.  They also agreed to settle the charges.

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