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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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2019 Mutual Funds and Investment Management Conference


Time to Read: 1 minutes Practices: Asset Management

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Ropes & Gray’s memorandum summarizing the 2019 Mutual Funds and Investment Management Conference sponsored by the Investment Company Institute and the Federal Bar Association is available above. The Conference included sessions that discussed the following industry and regulatory developments, among others:

  • Keynote Remarks by SEC Director of the Division of Investment Management Dalia Blass & Commissioner Elad Roisman.
  • Near-term initiatives of the SEC that include investor protections and reexamining proxy voting requirements.
  • The SEC’s current examination and enforcement focus areas.
  • Cybersecurity.
  • Liquidity risk management.
  • A review of developments in mutual fund civil litigation.
  • New operational and investment challenges affected by EU regulations.

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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