SEC Provides Revised Relief to Assist Registered Funds Affected by the Coronavirus

On March 25, 2020, the SEC issued a revised order superseding a prior order from March 13, 2020 providing relief from certain provisions of the 1940 Act for registered investment companies (funds) whose operations may be affected by the coronavirus (1940 Act Order). The 1940 Act Order addresses: (i) the in-person voting requirements for certain approvals under Sections 15(c) and 32(a) and Rules 12b-1 and 15a-4; (ii) the filing requirements relating to Forms N-CEN and N-PORT; (iii) the transmittal to shareholders of annual and semi-annual reports; and (iv) the notice filing requirements relating to Form N-23C-2.

The SEC’s press release and the 1940 Act Order are available at the links below:

https://www.sec.gov/news/press-release/2020-73

https://www.sec.gov/rules/other/2020/ic-33824.pdf

This Seward & Kissel memorandum describes the 1940 Act Order in greater detail: https://www.sewkis.com/publications/sec-provides-revised-relief-to-assist-registered-funds-affected-by-the-coronavirus/