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Asset Management ADVocate

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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:

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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

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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.

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Improving the Limited Derivatives User Provisions of Rule 18f-4

Our last post explained why the Limited Derivatives User provisions of

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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.

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Limited Derivatives Users—Applying the Currency Hedging Exclusion

Our last two posts surveyed what Rule 18f-4 and its adopting release (the "

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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).

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D&I Developments at the SEC - Part 1 of 2

In recent weeks two important regulatory developments focused on diversity and inclusion (D&I) have come out of the SEC: the D&I Subcommittee of the SEC's Asset Management Advisory Committee (AMAC) presented and received approval for its recommendations, and the SEC issued

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Rule 18f-4: Trimming Hedges—Hedges Included in Derivatives Exposure

This post continues our examination of how a fund must treat hedges when calculating its derivatives exposure to qualify as a limited derivatives user.

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Rule 18f-4: Trimming Hedges—Hedges Excluded from Derivatives Exposure

Our post on the derivatives exposure equation began with a separate equation concerning interest rate and currency hedges. This post explains the significance of this equation and what hedges should be excluded from a fund's derivatives exposure.

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No Summer Slump on ESG at the SEC: Board Duties, Exams, Rulemaking and Skepticism

This post catches up on the ESG front at the SEC following the appointment of Gary Gensler as Chairman.

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Derivatives Exposure: Adjusting for Multipliers

This post continues our discussion of the calculation of "gross notional amounts" included in a fund's "derivatives exposure" under Rule 18f-4.

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Derivatives Exposure: Adjusting Notional Amounts

Our previous post gave the best account we could of what the SEC staff has said about calculating the "gross notional amount" of derivatives transactions.

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Derivatives Exposure: A Circuitous Path to “Gross Notional Amounts”

In this post, we tackle the question of how to calculate the "gross notional amount" of a derivatives transaction for purposes of the limited derivatives user provision of Rule 18f-4.

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Perkins Coie Shepherds the First Registered Investment Company Structured as a Maryland Benefit Corporation

The U.S. Securities and Exchange Commission granted effectiveness to the registration statement of a client of Perkins Coie, which is the first known registered investment company structured as a Maryland Benefit Corporation.