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BDCs and New Fund of Funds Arrangements

The SEC recently adopted new Rule 12d1-4 (the Rule) under the 1940 Act intended to streamline the regulation of registered funds that invest in other registered funds and BDCs (“fund of funds” arrangements). Among other things, the Rule increases the limits now applicable to registered funds’ investments in BDCs.

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Expiration of COVID-19 Relief for APs and Principals to Submit Fingerprint Cards

Practices: Asset Management, Derivatives & Commodities

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On September 29, 2020, the U.S. Commodity Futures Trading Commission (‘CFTC”) Division of Swap Dealer and Intermediary Oversight announced (available here) that it had declined to extend its April 2020 COVID-19 relief granted in Letter 20-16 and extended to September 30, 2020 in Letter 20-20 (available here) from the requirement that a fingerprint card be submitted to the NFA in connection with the listing of a principal or registration of an associated person (“AP”). As a result, effective October 1, all persons applying for AP registration or to be listed as a principal of a registrant must submit fingerprint cards to the NFA. Persons who have relied on Letter 20-20 must submit fingerprint cards to the NFA by November 2, 2020.

Similarly, the NFA, on October 6, 2020, issued a Notice to Members (available here) confirming the expiration of relief that it had granted previously from the fingerprinting requirements in NFA Registration Rules 204(a)(2)(A) and 206(a)(1)(A).

Importantly, the NFA’s COVID-19 relief for members allowing APs to work from home without registering additional branch offices (as further discussed here) remains in effect for firms that continue to operate under their business continuity plans.

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Please contact Deborah A. Monson, Jeremy A. Liabo, Lindsey Jones or the Ropes & Gray attorney who usually advises you with any questions you may have or if you would like additional information.

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