The SEC recently adopted a new rule, Rule 12d1-4 (FoF Rule), 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.
The release adopting the amendments (Adopting Release) 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.
This Seward & Kissel client memorandum discusses the FoF Rule and other amendments included in the Adopting Release in more detail: Please Click Here
The Adopting Release is available: Please Click Here