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SEC Staff Takes No-Action Position Regarding Closed-End Funds’ Use of State Control Share Statutes

On May 27, 2020, the SEC’s Division of Investment Management published a statement (the “Statement”) that, effective immediately, withdraws the 2010 Boulder Total Return Fund no-action letter (the “Boulder Letter”), which concerned the interaction between Section 18(i) of the 1940 Act and a state control share acquisition statute (a “Control Share Statute”), and replaces the Boulder Letter with a new no-action position.

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2018 ICI Mutual Funds and Investment Management Conference


Time to Read: 1 minutes Practices: Investment Management

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Ropes & Gray’s memorandum summarizing the 2018 ICI Mutual Funds and Investment Management Conference sponsored by the ICI and the Federal Bar Association is available above. The Conference included sessions that discussed the following industry and regulatory developments, among others:

  • Near-term initiatives of the SEC that include the fund board outreach initiative, an exchange-traded fund rule, a shareholder report delivery rule and a best-interest standard of conduct.
  • The SEC’s current examination and enforcement focus areas.
  • The Tax Act of 2017.
  • A review of developments in mutual fund civil litigation.
  • The impact of EU regulations on the trading desks of global asset managers.
  • Developments affecting UCITS funds, including consequences of Brexit for UCITS managers.

If you would like to discuss a specific session, or any other aspect of the conference, please contact any of the lawyers listed on the back cover of the memorandum or the Ropes & Gray lawyer with whom you regularly work.

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