November 20, 2020
On November 19, 2020, the release reflecting the SEC’s adoption of Rule 12d1-4 (FoF Rule) under the 1940 Act and related amendments designed to implement a regulatory framework for investments by registered investment companies and business development companies (BDCs) (collectively, funds) in underlying funds was published in the Federal Register, which means that the various compliance and effective dates for the FoF Rule and related actions are now established. The release reflecting the SEC’s adoption of the amendments also rescinds Rule 12d1-2 (which applies to affiliated fund-of-funds arrangements) and prior exemptive relief that is covered by the FoF Rule and amends Rule 12d1-1 under the 1940 Act relating to fund-of-funds investments in money market funds.
The relevant compliance and effective dates are summarized below:
This Seward & Kissel client memorandum discusses the FoF Rule and other amendments included in the Adopting Release in more detail: https://www.sewkis.com/publications/sec-adopts-final-rule-amendments-for-fund-of-funds-arrangements/
The adopting release containing the various compliance and effective dates is available here: https://www.federalregister.gov/documents/2020/11/19/2020-23355/fund-of-funds-arrangements
November 27, 2024
November 19, 2024
November 12, 2024
November 11, 2024
November 5, 2024
November 4, 2024
November 1, 2024
October 31, 2024
October 24, 2024
October 9, 2024
October 8, 2024
The opinions expressed are those of the author(s) and do not necessarily reflect the views of the firm or its clients, or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice.
One Battery Park Plaza
New York, NY 10004
Phone (212) 574-1200
Fax (212) 480-8421
901 K Street, NW
Washington, DC 20001
Phone (202) 737-8833
Fax (212) 480-8421
Contact Us
General/Media Inquiries – info@sewkis.com
Legal Recruiting – recruiting@sewkis.com
Staff Recruiting – hr@sewkis.com
© 2024