In an interpretive letter dated January 11, 2017 (the “Staff Letter”), the Office of Chief Counsel of the Division of Investment Management stated its view that, under certain circumstances the restrictions of Section 22(d) of the Investment Company ...

Seward & Kissel LLP


40 Act Blog - 5 new articles


Division of Investment Management Provides Interpretive Guidance on Section 22(d) Restrictions

In an interpretive letter dated January 11, 2017 (the “Staff Letter”), the Office of Chief Counsel of the Division of Investment Management...

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SEC Issues No-Action Relief in Connection with the Reallocation of a Unitary Fee without Shareholder Approval

In a recent no-action letter, the staff of the Division of Investment Management (the “Staff”) indicated that it would not recommend enforcement...

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SEC No-Action Position on use of Affiliated Person as Broker to execute FX Transactions

In a recent no-action letter, the SEC provided assurances that it would not recommend enforcement action under Section 17(e) of the 1940 Act if...

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Two Firms Settle with SEC over Improper Valuations of Bonds

Two recent settlements between investment advisers and the Securities and Exchange Commission (“SEC”) demonstrate the importance of correctly...

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December 2016 Compliance Flash

Attached please find the December 2016 edition of the Compliance Flash. If you have any questions or comments, please contact your primary Investment...

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