March 24, 2021
As discussed in a recent S&K ’40 Act Blog Post, the staff of the SEC’s Division of Investment Management (staff) published a FAQ regarding the newly adopted Rule 2-a5 (Valuation Rule).
The staff recently added a new response to the FAQ that confirms that funds are not required to comply with the Valuation Rule’s definition of “readily available market quotations” with respect to cross trades undertaken in reliance on Rule 17a-7 until the rule’s compliance date (September 8, 2022). The response also states that the staff would not object if a fund voluntarily complies with the Valuation Rule prior to the compliance date but does not apply the new definition of “readily available market quotations” provided in the Valuation Rule to cross trades undertaken in reliance on Rule 17a-7 under the 1940 Act until the compliance date.
S&K will continue to provide updates on developments regarding the Valuation Rule. For more information on the Valuation Rule, please visit this S&K Memo.
November 29, 2023
November 6, 2023
October 26, 2023
October 18, 2023
October 17, 2023
October 10, 2023
October 6, 2023
September 29, 2023
September 25, 2023
September 22, 2023
September 20, 2023
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
© 2023