Asset Management ADVocate
Asset Management ADVocate
The Asset Management ADVocate provides unique analysis and insight into legal developments affecting asset managers in the United States.
Rule 18f-4 Wrap-Up
This post will bring to a close, for now, our survey of the requirements of new Rule 18f-4, which investment companies must comply with by Augu
Compliance with Rule 18f-4 by a Sub-Advised Fund
As with Fund-of-Funds, the release adopting Rule 18f-4 (the "Adopting Release") devotes a section to sub-advised funds. We again consider three types of funds:
Compliance with Rule 18f-4 by a Fund-of-Funds
The release adopting Rule 18f-4 (the "Adopting Release") devotes an entire section to discussing how "a fund that invests in other registered investment companies ('underlying funds')" should comply with the value-at
A Limited Derivatives User Punch List
In our extensive examination of the requirements for Limited Derivatives Users under Rule 18f‑4(c)(4) we have tried to be conscientious in pointing out matters open to interpretation.
Improving the Limited Derivatives User Provisions of Rule 18f-4
Our last post explained why the Limited Derivatives User provisions of
Limited Derivatives Users—Applying the Interest Rate Hedging Exclusion
Our last post examined examples of currency hedges that we believe Rule 18f‑4(c)(4)(i)(B) should allow a fund seeking to comply with the Limited Derivatives User requirements to exclude from its derivatives exposure.
Limited Derivatives Users—Applying the Currency Hedging Exclusion
D&I Developments at the SEC - Part 2 of 2
In Part 1 of this post, we focused on the July 7, 2021, recommendations for funds and advisers from the Diversity and Inclusion (D&I) Subcommittee of the SEC's Asset Management Advisory Committee (AMAC).
D&I Developments at the SEC - Part 1 of 2
Rule 18f-4: Trimming Hedges—Hedges Included in Derivatives Exposure
Rule 18f-4: Trimming Hedges—Hedges Excluded from Derivatives Exposure
No Summer Slump on ESG at the SEC: Board Duties, Exams, Rulemaking and Skepticism
Derivatives Exposure: Adjusting for Multipliers
Derivatives Exposure: Adjusting Notional Amounts