April 1, 2020
On March 26, 2020, the SEC staff (Staff) issued a no-action letter to the Investment Company Institute (ICI Letter) that provides temporary relief to registered open-end investment companies, other than exchange-traded funds and money market funds (open-end funds), and affiliated persons of such open-end funds (and affiliated persons of such affiliated persons) (Affiliates) from certain restrictions in Section 17(a) of the 1940 Act. Subject to conditions that are specified in the ICI Letter, the Staff will permit Affiliates to rely on Rule 17a-9 to purchase an affiliated open-end fund’s debt securities to enhance such fund’s liquidity or to fund shareholder redemptions in light of the short-term dislocation in the fixed income markets caused by the outbreak of COVID-19.
The ICI Letter is available at: Click Here
This Seward & Kissel memorandum discusses the ICI Letter in greater detail: Click Here
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